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flood was such a casualty. See also Ferguson v. Commissioner,
23 B.T.A. 364 (1931), remanded on other grounds 59 F.2d 893 (10th
Cir. 1932). See generally Rev. Rul. 76-134, 1976-1 C.B. 54. The
parties generally lock horns on the adjusted basis of each
single, identifiable property that was damaged by the flood and
the value of each of these assets both before and after the
flood.
Turning first to the need to identify each separate piece of
property damaged by the flood, we find that the record does not
allow us to do so. Although petitioner presented an expert at
trial who testified on the amount of the casualty loss that the
Property suffered as a whole, the expert did not identify each
separate piece of property that he believed suffered a loss.
The need to know each piece of property damaged by the flood is
essential to our determination because Trinity's deduction of any
loss caused by the flood's damage or destruction of property is
limited by that property's adjusted basis. Carloate Indus., Inc.
v. United States, supra at 817; see also United States v.
Koshland, 208 F.2d 636, 639-640 (9th Cir. 1953); Keefer v.
Commissioner, 63 T.C. 596 (1975).
Nor can we determine the basis or diminution in value of any
single, identifiable property. The regulations require that
petitioner identify each separate piece of property not only to
isolate the basis in that asset, but to determine the diminution
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