Perry H. Kay, Sr. - Page 19




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          value of the property immediately prior to the storm was                    
          presented at trial, petitioner has failed to provide the                    
          information necessary to apply the fair market value approach.              
          Thus, petitioner is not entitled to the $5,151.19 casualty loss             
          deduction claimed applying the fair market value approach.                  
               B.  Cost of Repairs Approach                                           
               At trial, petitioner presented many documents in his                   
          attempt to substantiate the casualty loss deduction applying the            
          cost of repairs approach.  The documents were stipulated by the             
          parties and are part of the record.  Petitioner presented a copy            
          of:  (1) The insurance settlement claim from State Farm in the              
          amount of $857.12; (2) a contract with Carl B. Adams to install a           
          new roof and replace rotten decking for $1,500; (3) three                   
          receipts from Carl B. Adams acknowledging payment of $1,500; (4)            
          a receipt to haul and dump roofing materials for $125; (5) two              
          receipts from Commercial Sand totaling $50; (6) three receipts              
          from Builders Square Store # 1409 totaling $123.64; (7) a receipt           
          from Olshan Lumber Company for $1,070.11; and (8) a credit                  
          invoice from Olshan Lumber Company for items returned in the                
          amount of $280.74.  Accordingly, petitioner presented                       
          documentation totaling $2,588.01 to replace his roof and received           
          $857.12 in insurance proceeds.  Thus, petitioner’s net out-of-              
          pocket expense was $1,730.88 (net expense).                                 
               Petitioner testified that he spent “over $4,000" to repair             






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