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acquired by either gift or inheritance, and petitioners offered
no evidence of their basis in the items. As to all of the items,
therefore, petitioners have failed to prove their tax basis in
the property.
The Court therefore sustains respondent's determination that
petitioners are not entitled to deduct on Schedule A, casualty
and theft losses totaling $37,222.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be
entered under Rule 155.
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Last modified: May 25, 2011