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Northridge earthquake were deducted as a casualty loss on her
1994 return, which respondent does not dispute. At the core of
petitioner’s case is her desire to recover some of the lost
insurance reward which she was denied because the condominium was
foreclosed.
On the basis of the above, we find that petitioner failed to
substantiate the amount of the casualty loss, and, therefore, it
is unnecessary for us to address respondent’s alternative
arguments. Accordingly, petitioner is not entitled to the
casualty loss deduction during the year in issue. Respondent is
sustained on this issue.
We have considered all arguments by the parties, and, to the
extent not discussed above, conclude that they are irrelevant or
without merit.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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Last modified: May 25, 2011