35- -
the automobiles before the February flood. Petitioners used the
amounts they claimed to have received as salvage value and trade-
in value for the automobiles after the February flood as the fair
market value of the automobiles after the February flood. They
used NADA's list of average retail values of automobiles to
determine the fair market value of the automobiles before the
February flood.
Petitioners claimed to have received $335 in salvage value
for the 1984 Nissan 300ZX and $2,000 in trade-in value for the
1989 Honda Accord. NADA lists the average retail value of a 1984
Nissan 300ZX Coupe Turbo GL as $6,525, and the low mileage
premium to be added to a standard size car with 7,501 to 15,000
miles as $2,400, or a total of $8,925. The average retail value
of a 1989 Honda Accord Sedan LXi and its applicable low mileage
premium, which petitioners used to determine the retail value of
the 1989 Honda Accord, are illegible in the photocopied NADA
pages submitted by petitioners.
Petitioners, however, presented no evidence, other than
their uncorroborated testimony, showing how much they received in
salvage or trade-in value for the two automobiles. And they
presented no evidence proving the model, features, or mileage of
either car. Thus, we agree with respondent that petitioners
failed to prove the amounts of such losses. Consequently, they
are not entitled to deduct a casualty loss on their 1991 return
for damage to the two automobiles.
Page: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 NextLast modified: May 25, 2011