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v. Bellefonte Ins. Co., 677 F.2d 1365, 1369 (11th Cir. 1982).
Inasmuch as the owner is an interested witness, the task of the
trier of fact is to evaluate the credibility of the owner’s
testimony. Neff v. Kehoe, supra; J & H Auto Trim Co. v.
Bellefonte Ins. Co., supra. Petitioner’s testimony lacks
credibility because he was not trained or qualified to determine
the amount of the decrease in value of his home or beach lot as a
result of the damage alleged.
Tank v. Commissioner, 270 F.2d 477 (6th Cir. 1959), revg. 29
T.C. 677 (1958), cited by petitioners, is distinguishable from
the case at hand. There the Court of Appeals for the Sixth
Circuit reversed a casualty loss disallowance by this Court and
allowed the loss, relying not only on the taxpayers’ own
testimony, but also on evidence of cause of the loss by a
licensed architect and evidence of the loss of value by a real
estate appraiser.
Even assuming, on the basis of petitioner’s status as a
leading citizen of Atmore with knowledge of local conditions,
that he was an expert on local property values, we have broad
discretion to evaluate “‘the overall cogency of each expert’s
analysis.’” Sammons v. Commissioner, 838 F.2d 330, 334 (9th Cir.
1988) (quoting Ebben v. Commissioner, 783 F.2d 906, 909 (9th Cir.
1986), affg. in part and revg. in part T.C. Memo. 1983-200),
affg. in part and revg. in part on another ground T.C. Memo.
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