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in the value of that asset on account of the flood. Trinity may
not deduct a diminution in the value of undamaged property, even
if that diminution is indirectly related to the damage caused to
other property. See Thornton v. Commissioner, 47 T.C. 1, 6
(1966). Petitioner has not proven the diminution in value of the
Property as a whole, let alone the diminution in value of any of
the separate parts thereof.3
We hold for respondent. To the extent that petitioner
argues for a contrary holding, we have considered all his
arguments and, to the extent not discussed above, find them to be
irrelevant or without merit.
To reflect the foregoing,
Decision will be entered
for respondent.
3 In this regard, we are unpersuaded by the testimony of
petitioner's expert on the diminution in the value of the
Property as a whole. We are not required to adopt that
testimony, Helvering v. National Grocery Co., 304 U.S. 282, 294-
295 (1938), and we do not.
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