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sustain respondent's determination disallowing those deductions
for the 1997 and 2000 taxable years.
Casualty Loss
Respondent disallowed petitioners' claimed casualty loss of
$4,516 for 2000. Under section 165(c)(3), a taxpayer may deduct
property losses not compensated by insurance or otherwise,
arising from fire, storm, shipwreck, or other casualty or from
theft. To qualify as a casualty, the event causing the loss must
be sudden and not the result of deterioration over time. Maher
v. Commissioner, 680 F.2d 91, 92 (11th Cir. 1982), affg. 76 T.C.
593 (1981); Coleman v. Commissioner, 76 T.C. 580, 589 (1981).
Respondent conceded on brief that petitioners incurred a
casualty loss from flooding in April 2000. Respondent further
conceded $1,090 of casualty losses substantiated by petitioners
after the petition was filed.22 The remaining $3,426 in claimed
casualty losses is still in dispute, and respondent maintains
that these losses should be disallowed because petitioners have
failed to substantiate them.
Petitioners describe the unsubstantiated amounts as covering
a "box of valuables", two chainsaws, two dehumidifiers, and
approximately $3,000 in clothing and bedding damaged in the
flood. Petitioners have offered no evidence to corroborate these
additional losses claimed. Accordingly, we hold that petitioners
22 This amount covers substantiated costs of replacing a
water heater, furnace, and sump pump.
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