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casualty loss amount on Form 4684, Casualties and Thefts,
applying the fair market value approach. On Form 4684,
petitioner reported the fair market value of the property before
and after the casualty to be $60,000 and $52,870, respectively.
The $7,130 difference in the fair market values reported was
first reduced by $100, then further reduced by $1,888.81, 10
percent of the adjusted gross income shown on the return.
Thereby, petitioner computed a casualty loss of $5,151.19. No
insurance reimbursement was reported on the Form 4684.
A. Fair Market Value Approach
At trial, petitioner offered no evidence to substantiate the
fair market values reported on Form 4684. Petitioner did present
a Uniform Residential Appraisal Report (report), which estimated
the market value of petitioner’s residence, as of October 10,
1998, to be $53,000. The report makes no mention of the damage
claimed by petitioner, nor states that the appraised amount was
based on a value before or after the date of the storm. Because
the appraised value was determined as of October 10, 1998,
approximately 1 month after the storm and before any repairs were
made, we believe the $53,000 figure represents the fair market
value of the property taking into consideration any damage
resulting from the storm.6 Since no evidence of the fair market
6 The Uniform Residential Appraisal Report states that
Oct. 10, 1998, was the date of inspection of the property.
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