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other basis” in the damaged property items. Petitioner then
totaled the fair market values of the damaged property items by
categories: clothing, tools, electronics and appliances (as shown
above). Petitioner then “depreciated” the total amount of the
category by a percentage she felt was fair. It appears that
petitioner had no reasoning for the amount chosen to “depreciate”
each category. Petitioner then calculated her casualty loss by
using the sum of all the depreciated values and applying the
limitations of section 165(h).
Petitioner did not attempt to obtain actual receipts for any
of the damaged items. Petitioner did not call as witnesses to
substantiate the casualty loss, Mr. Davis, who allegedly helped
her pump the water out of her basement and helped her dispose of
the damaged or destroyed items of personal property, or any other
individual.
Petitioner has presented no reliable evidence of any repairs
made to her single-family home or to the personal property items
that were damaged or destroyed as a result of the flood.
Petitioner has offered as evidence to support that she actually
sustained a casualty loss: (1) A receipt issued by Mr. Davis
that purports to identify the items lost in the purported flood
of her basement; and (2) petitioner’s own testimony. Petitioner
has provided as evidence to support the amount of the actual
casualty loss: (1) Petitioner’s estimate of the cost of each
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