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steadily operating cause. Fay v. Helvering, 120 F.2d 253 (2d
Cir. 1941), affg. 42 B.T.A. 206 (1940). In considering whether
termite damage qualified as a casualty, we have held that the
“suddenness” of the loss itself (the lapse of time between the
precipitating event and the loss proximately caused by that
event) is a determining factor. Maher v. Commissioner, 76 T.C.
593, 599-600 (1981), affd. 680 F.2d 91 (11th Cir. 1982); Pryor v.
Commissioner, T.C. Memo. 1987-80.
Respondent, relying upon the cases relating to progressive
deterioration, suggests that the failure of the hose connection
and ensuing damage to the house and personal property do not
constitute a casualty, because the deterioration occurred during
an extended period of time. In this regard, it would appear
appropriate to separate (1) the damage to the washing machine
hose from (2) the consequential water damage resulting from the
failure of the hose. We conclude that the damage to the washing
machine hose resulted from progressive deterioration. The
washing machine was included with the purchase of the house in
1985. Thus, the washing machine and hose connection were at
least 9 years old when the hose failed. It is not unusual that a
rubber hose would deteriorate over a period of years and
ultimately fail. We conclude that the failure of the washing
machine hose was the result of progressive deterioration and not
the result of a sudden event. Thus, the failure of the hose does
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