- 9 - 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 valuePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011