Estate of James W. Boyle - Page 14




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          old warehouse did not exceed the insurance recovery of                      
          $553,793.11  Accordingly, we sustain respondent’s determination             
          disallowing the Boyles’ 1995 casualty loss.                                 
               We have carefully considered all remaining arguments made by           
          petitioners for contrary holdings, and, to the extent not                   
          discussed, we find them to be irrelevant, moot, or without merit.           
               To reflect the foregoing,                                              


                                                  Decision will be entered            
                                             for respondent.                          


















               11Petitioners failed to offer any evidence regarding the               
          starting and completion dates of the reconstruction.                        
          Petitioners’ position regarding the Boyles’ adjusted basis for              
          purposes of sec. 165 assumes that both the insurance recovery and           
          the construction of the new warehouse occurred in 1995.  This               
          assumption seems questionable, but we need not examine it further           
          under the circumstances.                                                    





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