36-  -                                        
               4.  April Flood                                                        
               With respect to the April flood damage to petitioners' home            
          and its contents, an insurance adjuster for ABIC determined, and            
          ABIC paid to petitioners, insurance reimbursement of $39,059.91,            
          consisting of $27,372.91 for damage to the home and $11,687                 
          reimbursement for damage to its contents.  On their 1991 Federal            
          income tax return petitioners claimed a loss of $143,064.34,                
          before insurance reimbursement, for damage to their home caused             
          by the April flood.  At trial, they reduced the claimed loss to             
          $99,383.28, before insurance reimbursement, consisting of a                 
          $79,863.28 loss claimed for damage to their home and a $19,520              
          loss claimed for damage to its contents.                                    
               Respondent contends that petitioners have failed to                    
          establish that the amount of the April flood loss is either the             
          amount claimed on their 1991 return or the reduced amount claimed           
          at trial.                                                                   
               Petitioners failed to establish by competent appraisal the             
          fair market value of their home and personal property before and            
          after the April flood.  It is petitioners' position that the cost           
          to repair their home is the measure of its decrease in fair                 
          market value as a result of the damage caused by the April flood.           
               Petitioners calculated the $79,863.28 claimed loss to their            
          home by totaling the amount they claim to have spent repairing              
          their home as a result of the April flood.  Their evidence does             
          not substantiate the amount claimed.  The total amount of a                 
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