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damage to property must qualify as a casualty. See, e.g., White
v. Commissioner, 48 T.C. 430 (1967); Durden v. Commissioner, 3
T.C. 1 (1944). Second, the nature of the damage sustained must
be such that it is deductible for purposes of section 165. See,
e.g., Squirt Co. v. Commissioner, 51 T.C. 543 (1969), affd. 423
F.2d 710 (9th Cir. 1970); Pulvers v. Commissioner, 48 T.C. 245
(1967), affd. 407 F.2d 838 (9th Cir. 1969); Citizens Bank v.
Commissioner, 28 T.C. 717 (1957), affd. 252 F.2d 425 (4th Cir.
1958); Kamanski v. Commissioner, T.C. Memo. 1970-352, affd. 477
F.2d 452 (9th Cir. 1973). At issue here then are whether the
events surrounding the alleged Simpson murders and affecting
petitioners’ property can properly be termed a casualty and
whether the type of loss suffered by petitioners as a consequence
of these events is recognized as deductible. We conclude that
both inquiries must be answered in the negative.
A. Nature of Occurrence Constituting a Casualty
The word “casualty” as used in section 165(c)(3) has been
defined, through application of the principle of ejusdem generis,
by analyzing the shared characteristics of the specifically
enumerated casualties of fire, storm, and shipwreck. See, e.g.,
White v. Commissioner, supra at 433-435; Durden v. Commissioner,
supra at 3-4. As explained by this Court:
wherever unexpected, accidental force is exerted on
property and the taxpayer is powerless to prevent
application of the force because of the suddenness
thereof or some disability, the resulting direct and
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