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Petitioner’s schedule of loss on the 1998 return reflects the
fair market value of personal property before the casualty as
$112,059 and the fair market value after the casualty as $5,580.
We are satisfied that petitioner did incur some loss. Most of
petitioner’s personal belongings, including clothing,
furnishings, carpeting, and books, were completely destroyed. We
accept petitioner’s assertion as to the fair market value after
the casualty, namely $5,580. We, however, do not accept
petitioner’s assertion as to the fair market value before the
casualty and instead do our best to approximate a reasonable
value. Cohan v. Commissioner, 39 F.2d 540, 544 (2d Cir. 1930).
Further, petitioner is not entitled to a deduction for moving or
storage costs since such expenditures do not represent a loss of
property value. Millsap v. Commissioner, 46 T.C. 751, 762
(1966), affd. 387 F.2d 420 (8th Cir. 1968). Accordingly, the
6(...continued)
record in an attempt to make some rational sense of petitioner’s
confusing records.
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