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and confusing. Nevertheless, we are satisfied that she suffered
a loss and do our best to reconstruct the amount of the loss. In
this connection, the claimed loss falls into two categories:
(1) Real property (the house), and (2) personal property.
With respect to the real property loss, petitioner claims
that the fair market value of the house immediately before the
casualty was $142,000 and that the fair market value immediately
after the casualty was $100,000. Petitioner testified that she
received an appraisal of the house before the casualty; however,
she did not present it to the Court. Ordinarily an appraisal is
required. Sec. 1.165-7(a)(2)(i), Income Tax Regs. As previously
indicated, the regulations also permit the cost of repairs as
evidence of the amount of loss. Sec. 1.165-7(a)(2)(ii), Income
Tax Regs. However, this must be the cost of repairs actually
made, not merely an estimate of the cost. Lamphere v.
Commissioner, 70 T.C. 391, 395 (1978). Further, the sale of the
house by foreclosure in 1995 for $100,000 (the same amount
reflected as the cost basis in 1984) does not provide us with a
means of determining the amount of any loss. There is not
sufficient evidence in this record to allow petitioner any loss
with respect to the house itself.
We now consider the amount of the loss with respect to
personal property. Petitioner claimed a loss of $106,479.6
6 We note that petitioner submitted not less than four
separate and different schedules of claimed loss. We have
reviewed and considered all the schedules of claimed loss in this
(continued...)
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