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on petitioners’ 1994 return. Hence, to clarify the position
being taken and the reasons underlying petitioners’ deduction, an
explanatory supplemental statement labeled “Casualty Loss” was
attached to the return. After indicating the location of
petitioners’ property in relation to that of Simpson, it stated
that the casualty loss was premised on “the calamity of the
murder & trial, which was sudden & unavoidable & which resulted
in a permanent loss to value of property.” A table enumerating
instances of minor physical damage to petitioners’ property, such
as damage to lawn and sprinklers, was also attached to the
return, but no valuation was placed upon the harm caused thereby.
At the time petitioners purchased their property, they were
aware that the existing home required remodeling and repair. In
the fall of 1994, petitioners demolished most of the house.
Then, in March of 1995, they began a reconstruction project
costing approximately $2 million. This reconstruction was
completed in December of 1996, and petitioners moved into the
residence. Petitioners continued to reside at 359 North Bristol
Avenue up to and through the date of trial.
Other residents of Brentwood Park have undertaken similar
reconstruction projects in recent years. The Nebekers, who own
the property across Ashford Street from the former Simpson
residence, are proceeding with a $1 million remodeling of their
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