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home. Likewise, the property owned by Simpson was sold after he
moved out in 1998, the existing house was demolished, and a new
residence is currently being constructed.
As of early 1999, the area surrounding the former Simpson
home was no longer inundated with media personnel or equipment.
The police barricades restricting traffic in the immediate
vicinity of petitioners’ property had been removed. Looky-loos,
however, continued to frequent the neighborhood, often advised of
the location of Simpson’s former residence by its inclusion on
“star maps” published for the Los Angeles area. Anniversaries of
the murders were also typically accompanied by periods of
increased media and public attention.
OPINION
We must decide whether petitioners are entitled to a
casualty loss deduction based upon a postulated decline in the
value of their residential property and, if not, whether they are
liable for the section 6662(a) accuracy-related penalty.
Petitioners contend that the media and onlooker attention
following the murders and focusing on Simpson’s home has
decreased the value of their adjacent property. They argue that
because the homicides were a sudden, unexpected, and unusual
event, and because aspects of the public interest precipitated
thereby continued at least to the time of trial in this case,
they have suffered a permanent casualty loss. Petitioners
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