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to support his contention that he attempted to file an insurance
claim as a result of the flood.
Petitioner also testified as to his calculation of his
claimed casualty loss deduction. Petitioner calculated such
casualty loss deduction by inventorying the damaged and destroyed
carpeting and personal property items as they were “hauled away”.
He then found purchase receipts for these items. Petitioner
“depreciated” all items by 10 percent of their purchase price, no
matter how long he had owned the item. Petitioner then
calculated his casualty loss by using the sum of all the
depreciated values and applying the limitations of section
165(h).
Petitioner did not attempt to recreate the above-described
inventory list of items that were damaged or destroyed.
Petitioner did not attempt to obtain receipts for repairs to the
premises. Petitioner did not call, as witnesses to substantiate
the casualty loss, any of the individuals who allegedly helped
him pump the water out of his basement or helped him dispose of
the damaged or destroyed items of personal property.
Petitioner has presented no reliable evidence of any repairs
made to his townhouse or to the personal property items that were
damaged or destroyed as a result of the flood. The only evidence
presented by petitioner to support his claimed losses is his own
self-serving testimony. This Court is not bound to accept a
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Last modified: May 25, 2011