Tracy M. Colter and Robert N. Colter, Jr. - Page 10




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          casualty” do not appear to be based upon information contained on           
          the inventory.                                                              
          At trial, petitioners more or less ignored the computation                  
          of the casualty loss deduction set forth in their return.                   
          Instead, they relied almost exclusively on the inventory, a                 
          document prepared not with reference to the amount of any                   
          potential casualty loss deduction to which they might be                    
          entitled, but rather in connection with an insurance claim under            
          a policy that allowed recovery based upon replacement cost.  For            
          insurance purposes, the original cost of personal property                  
          damaged or destroyed in the fire was not particularly important.            
          Consequently, the inventory does not provide sufficient                     
          information to allow for the proper computation of the amount of            
          petitioners’ casualty loss deduction.  Nevertheless, respondent,            
          in apparent recognition of the practical difficulties confronting           
          petitioners in establishing the information technically required            
          to support a casualty loss deduction, relies, at least in part,             
          upon the information reported on the inventory, even though that            
          document might not contain all of the information necessary to              
          properly compute the allowable deduction.  In an apparent attempt           
          to simplify the matter, respondent now accepts petitioners’                 
          estimate of replacement costs and Westfield’s estimate of actual            
          cash value (replacement cost less depreciation) of the destroyed            
          property as the measure of that property’s fair market value                






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