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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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