31- -
year 1988. Thus, their claimed cost basis ($23,700) in this
computer equipment should have been reduced by the claimed
depreciation and section 179 expense by $2,740, which results in
a $20,960 adjusted basis. Sec. 1016(a)(2)(A).
Even if petitioners had included the proper adjusted basis
of their computer equipment in their $58,202.28 total claimed
cost basis, however, they have failed to prove that they were
entitled to calculate their claimed casualty loss based on the
original cost of the contents of their home, rather than using
the decrease in the fair market value of the contents of the
residence as the appropriate measure of their sustained casualty
loss.
We are not persuaded by petitioners' evidence that the loss
to the contents of their home is $58,202.28 as a result of the
February flood. The total amount of the invoices submitted by
them does not approach $58,202.28.
Petitioners also presented no evidence that the amount they
claim as the cost to repair the contents of their home is not
greater than necessary to restore the contents to their condition
prior to casualty. Such evidence is required by section 1.165-
7(a)(2)(ii), Income Tax Regs.
We have found it difficult to determine with reasonable
accuracy the amount of the loss sustained by petitioners in the
February flood. Again, petitioners contend that we should
approximate the loss sustained by them as a result of the
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