Francis N. and Patricia A. Leonard - Page 8

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          820, 823 (1964), affd. 354 F.2d 988 (9th Cir. 1965).  We have               
          also held that wood rot damage may qualify as a casualty loss if            
          it was of “comparatively recent origin so as to qualify for the             
          requisite degree of ‘suddenness’.”  Id. at 823-824; see also                
          Kilroe v. Commissioner, 32 T.C. 1304 (1959).  In this regard, the           
          burden is on petitioners to prove their entitlement to a casualty           
          loss deduction.  Rule 142(a); Welch v. Helvering, 290 U.S. 111              
          (1933).                                                                     
               Respondent contends that the collapsed deck and related                
          damage to the house do not give rise to a casualty loss deduction           
          because the loss is attributable to deterioration that occurred             
          during an extended period of time.  Petitioners contend that if             
          wood rot was the cause of the collapse of the deck, it was                  
          “hidden” and they “were not aware of it.”                                   
               After inspection by Farmers Insurance, it was determined               
          that the cause of the collapse of the deck was wood rot and                 
          deterioration.  Although concealed, after the collapse of the               
          deck, the wood rot became obvious, even to petitioners.  Nothing            
          in the record suggests that the wood rot was a “sudden”                     
          occurrence, or that it did not progress, as it usually does, over           
          an extended period of time.  Hoppe v. Commissioner, supra.                  
               The collapse of petitioners’ deck was the result of wood rot           
          and deterioration.  The damages and losses resulting from the               
          collapse of the deck were not caused by a “sudden” event, and               






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