Milton Craig Werner and Barbara K. Werner - Page 7

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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               
                                                  Decision will be                    
                                             entered under Rule 155.                  

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