Tracy M. Colter and Robert N. Colter, Jr. - Page 5




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          category of items) listed on the inventory, petitioners made                
          entries in designated columns for:  (1) Number of items                     
          destroyed; (2) date and place of purchase; (3) “original cost”;             
          and (4) replacement cost at or about the time of the fire.                  
               For a few items, there is a variance between the entries               
          made for original cost and the replacement cost.  For most, if              
          not all, of those few items, the replacement cost is higher than            
          petitioners’ estimated original cost for that item.                         
               For most items, either the amounts entered for original cost           
          and the replacement cost are identical, or, if more than one item           
          was destroyed, the replacement cost listed is the product of the            
          number of items multiplied by the amount listed as the original             
          cost of the items.  It appears that for these items, amounts                
          entered in the “original cost” column do not, as the name                   
          suggests, represent petitioners’ costs of the items, but instead            
          duplicate petitioners’ estimate of the replacement costs of those           
          items.                                                                      
               From the information supplied by petitioners, Westfield                
          computed the “actual cash value” of each item listed on the                 
          inventory by applying a depreciation factor, ranging from 20                
          percent to 70 percent, to the replacement cost of each item.  The           
          total of the amounts listed as original cost cannot be determined           
          from the copy of the inventory placed into the record because               
          relevant portions of the document are obscured by overlays.                 






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