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value of the custom house before the time in October 2000 when
petitioner alleges he discovered certain aspects of the alleged
custom house theft. Instead, the October 28, 2002 appraisal
report purported to determine the diminished value of the custom
house as of October 1, 2002.
With respect to the adjusted basis of Ms. Davis and peti-
tioner in the custom house, in the November 8, 2002 letter that
Ms. Davis and petitioner sent to the Maryland Attorney General,
they stated that they paid more than $1 million for the custom
house. Petitioner failed to introduce any evidence that corrobo-
rated that statement. Nor did petitioner introduce any evidence
that otherwise established the adjusted basis of Ms. Davis and
himself in the custom house (or in any property that was part of
the custom house and that was allegedly stolen, including the
bricks and humidifiers that were the subject of the alleged brick
theft and the alleged humidifier theft).
On the record before us, we find that petitioner has failed
to carry his burden of establishing the fair market value of the
custom house before the time in October 2000 when petitioner
alleges he discovered certain aspects of the alleged custom house
theft and the adjusted basis of Ms. Davis and petitioner in the
custom house (or in any property that was part of the custom
house). On that record, we further find that petitioner has
failed to carry his burden of establishing the amount of the loss
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