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cost in Saigans was not incurred as petitioner’s goods were moved
between New York City, petitioner’s former residence, and
Berkeley, petitioner’s new residence. Therefore, the storage
cost incurred by petitioner in Saigans was not incurred in
transit during petitioner’s move from New York City to Berkeley.
Accordingly, the Saigans storage cost is not a deductible moving
expense for purposes of section 217(a).
However, petitioner’s AAAAA Storage expense was incurred
during the 30-day period after the goods were moved from
petitioner’s former residence, New York City, and before delivery
at petitioner’s new residence, Berkeley. Accordingly, we hold
that petitioner is entitled to an additional moving expense
deduction under section 217(a) in the amount of $79 for the in-
transit storage expense.
E. Cost of Box Lost in Transit
Petitioner has failed to substantiate the claimed loss of
$2,350 with respect to the box lost in transit from New York City
to Berkeley. Petitioner did not offer any evidence other than
his testimony with respect to the cost or value of the contents
of the box. There is no basis in the record for the Court to
estimate such an expense under the Cohan rule. As such, we need
not decide whether the value of the box that petitioner claims
was lost by the moving company is a deductible moving expense for
purposes of section 217. Accordingly, we hold that petitioner is
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