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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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