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are applicable. See sec. 1.170A-13(a)(1), Income Tax Regs.
Under that regulation, the taxpayer need only have a receipt from
the donee containing the name and address of the donee, the date
and place of the contribution, and a description of the property.
Sec. 1.170A-13(b)(1), Income Tax Regs. We find that petitioner
has satisfied the requirements of section l.170A-13(a)(1), Income
Tax Regs., with respect to the remaining items and is entitled to
a $600 charitable contribution deduction.
Casualty Loss
Petitioner claims a casualty loss deduction in the amount of
$710.38. Respondent argues that the loss in question was not a
casualty but instead deterioration, and that petitioner has in
any event presented no evidence of the amount of the loss.
Petitioner experienced flooding in one room of her house that was
lower than the rest of the structure. Such flooding had not
occurred prior to 1993, but in that year it happened several
times during a 1- to 2-month period. Section 165(c)(3) allows a
deduction for losses arising from “fire, storm, shipwreck, or
other casualty”. A casualty is a sudden, unexpected loss, not
steady deterioration over time. Durden v. Commissioner, 3 T.C. 1
(1944). We need not decide whether petitioner’s loss was a
casualty, because we find that she has not proved the amount of
the loss. The measure of the deduction is the difference in the
fair market value of the house before and after the loss, not to
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