Arlan L. Rower and Sandra M. Howard - Page 22

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          that those receipts represent the replacement value of certain of           
          their personal property that was destroyed as a result of the               
          1994 Northridge earthquake.  However, there is no evidence in the           
          record showing that two televisions, a television base, and a               
          video cassette recorder were destroyed in the 1994 Northridge               
          earthquake or that the purchases represented by the receipts from           
          Circuit City Stores constituted replacement of such alleged                 
          destroyed property.  On the instant record, we find that peti-              
          tioners have failed to establish that the 1994 Northridge earth-            
          quake destroyed two televisions, a television base, and a video             
          cassette recorder.                                                          
               Based on the entire record before us, we find that petition-           
          ers have failed to show that they are entitled for 1993 to a                
          casualty loss deduction.  Consequently, we sustain respondent's             
          determination disallowing the casualty loss deduction that                  
          petitioners claimed in their 1993 return, and we reject petition-           
          ers' contention that they are entitled to the casualty loss                 
          deduction that they claimed in their 1993 amended return.                   
          Section 6662(a)                                                             
               Respondent determined that petitioners are liable for 1993             
          for the accuracy-related penalty under section 6662(a) because              
          the underpayment of income tax for that year was attributable to            
          negligence.  Petitioners contend that they have demonstrated that           







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