34- -
$14,763. Petitioners have failed to prove otherwise. Therefore,
we sustain respondent's determination on this issue.
3. Claimed Casualty Loss Deduction on Automobiles
Petitioners claimed additional casualty losses on their 1991
return for damage to a 1984 Nissan 300ZX automobile and a 1989
Honda Accord automobile in the amounts of $8,565 and $11,000,
respectively.
Respondent contends that petitioners failed to prove that
they sustained a loss to either automobile as a result of the
February flood.
In support of the claimed casualty losses to the two
automobiles, petitioners testified that both automobiles were
damaged by the February flood. However, they presented no
evidence showing that they owned either automobile and no
evidence, other than their uncorroborated testimony, showing that
the automobiles were damaged by the February flood. Thus, we
agree with respondent that petitioners failed to prove that they
sustained losses on the two automobiles.
Respondent also contends that, even if petitioners had shown
that they sustained losses on the automobiles, they failed to
prove the amounts of such losses.
Petitioners calculated the amount of their claimed losses to
the automobiles by subtracting the amount they determined to be
the fair market value of the automobiles after the February flood
from the amount they determined to be the fair market value of
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