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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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