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from theft.9
Petitioners attempted to satisfy their burden of proof with
respect to the casualty loss deduction claimed for 1997 through
Ms. Stoddard’s testimony and 14 photographs of the Quissett that
are part of the instant record. With respect to Ms. Stoddard’s
testimony, we found that testimony to be general, conclusory,
and/or uncorroborated in certain material respects. We shall not
rely on her testimony to sustain petitioners’ burden of proof
with respect to the casualty loss deduction claimed for 1997.
With respect to the photographs of the Quissett on which
petitioners rely, Ms. Stoddard testified that 12 of the 14
photographs show the Quissett during and after repairs and/or
“restoration work” that petitioners undertook before the alleged
storm and that 2 of the 14 photographs show the Quissett after
the alleged storm caused the damage that petitioners are claim-
ing. The back side of each of 4 of the 12 photographs that Ms.
Stoddard testified show the Quissett before the alleged storm
contain handwritten notations indicating that each of those
photographs was taken sometime during 1993 and 1994 (i.e., before
the alleged storm). The remaining eight photographs that Ms.
Stoddard testified show the Quissett before the alleged casualty
do not contain any indication as to when they were taken. The
9Petitioners do not contend that the alleged damage with
respect to the Quissett was a loss incurred in a trade or busi-
ness or in any transaction entered into for profit. See sec.
165(c)(1) and (2).
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