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the Atmore residence as a result of Hurricane Georges. On their
1997 return, petitioners claimed a casualty loss of $211,504 for
reduction in the fair market value of the Atmore residence as a
result of water damage to the exterior brick and the wooden frame
in the gables of the Atmore residence (the brick damage) caused
by Hurricane Georges. Petitioners also claimed a loss in the
architectural value of the Atmore residence as a result of having
to cover the exterior brick with vinyl siding in order to prevent
future water damage to the exterior brick. Although there is no
evidence in the record of the exact cost of the vinyl siding,
according to petitioner, the cost was “not very high”.
Photographs of the vinyl siding and the brick damage are in
evidence. Petitioners reported an insurance reimbursement of
$2,654 for damages as a result of Hurricane Georges. Petitioner
was not sure whether the insurance company paid any amount
towards repairing the brick damage or installing the vinyl
siding.
2. Beach Lot
Petitioners made a timely election under section 165(i) on
their 1997 return to claim a casualty loss from beach erosion of
their undeveloped beach lot in Baldwin County, Alabama, on the
Gulf of Mexico (the beach lot) as a result of Hurricane Georges.
Petitioners claimed a loss of the full amount of their $92,000
cost basis in the beach lot. Photographs of the beach and the
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