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value immediately before and after the casualty. Sec.
1.165-7(b)(1), Income Tax Regs.
Petitioners’ only evidence in support of the amounts of the
claimed losses was petitioners’ self-serving estimates of the
decrease in fair market values of their properties. Petitioners
introduced no documentary evidence or expert testimony, such as
an appraisal from a competent professional, to ascertain the
difference in fair market values of the Atmore residence or beach
lot before and after the natural disasters. See sec. 1.165-
7(a)(2)(i), Income Tax Regs.
Petitioners failed to introduce into evidence the assessor’s
appraisal of the Atmore residence that they claim was consistent
with their estimate of the decrease in the fair market value of
the Atmore residence after the 1997 earthquakes, even though the
Court held the record open for 30 days to allow them to do so.
Petitioners’ failure to introduce the assessor’s appraisal within
their possession and which, if true, would be favorable to them,
gives rise to the presumption that if produced, the assessor’s
appraisal would be unfavorable. See Wichita Terminal Elevator
Co. v. Commissioner, supra.
Although an owner of property is competent to testify
regarding its value, the weight of such testimony is affected by
the owner’s knowledge of circumstances which affect value. Neff
v. Kehoe, 708 F.2d 639, 644 (11th Cir. 1983); J & H Auto Trim Co.
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