25- -
Neither testified or qualified as an expert. Mrs. Oliver offered
only her uncorroborated testimony that Mr. Bernardi often does
such estimates. Petitioners obtained Mr. Hester's estimate in
1993, several years after the claimed damage occurred, and thus
we seriously doubt whether it was an accurate estimate of the
cost to repair damage that occurred in 1988.
The estimates made by Mr. Bernardi and Mr. Hester do not
show the decrease in fair market value of the home caused by the
1988 storm. Petitioners have presented no reliable evidence of
the repairs made to the home as a result of the storm. An
estimate of the cost to repair damage caused by a casualty
ordinarily does not establish the amount of the casualty loss, as
contemplated by section 1.165-7(a)(2)(i) and (ii), Income Tax
Regs., unless the repairs are actually made. Lamphere v.
Commissioner, 70 T.C. 391, 396 (1978).
Furthermore, even if the repairs detailed in the estimates
were made, petitioners have not shown that the amount of repairs
was no greater than necessary to restore the home to its
condition prior to the storm, as required by section 1.165-
7(a)(2)(ii), Income Tax Regs. Indeed, their home underwent a
major renovation which increased its size from 3,700 square feet
before the storm to approximately 9,000 square feet after the
storm.
Likewise, petitioners' Personal Property Inventory Booklet
is not persuasive to show that they sustained losses to their
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