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recover the value of the house. Even if we were to assume,
however, for purposes of argument, that 2001 was the proper year
for petitioners to claim a deduction for the alleged destruction
of their house in 1994, petitioners have failed to prove the fair
market value of the house or to produce evidence that would allow
us to reasonably estimate its value.4 Furthermore, petitioners
have failed to prove their adjusted basis in the house, thereby
4 Petitioners’ explanations as to their lack of supporting
documentation are unconvincing and unsatisfactory. At trial, in
response to an inquiry as to whether he had evidence as to the
amount of unreimbursed loss, petitioner husband stated
incongruously: “Yes, sir. I don’t have that. I don’t know if I
have it or not.” Petitioner husband testified that at least some
of the relevant documents were in a trailer that “was stolen by
two people who worked for the government.” Petitioner husband
initially testified that petitioners “didn’t have the money to
get the trailer back.” Subsequently, petitioner husband
testified, inconsistently: “even after we got the trailer, we
didn’t have, we couldn’t move it. We had no way to move the
trailer from off the person’s property to where we could go
through it.” Petitioner husband also testified that although
petitioners had additional records in a “storage facility” with
“files all the way to the door”, they were unable to open the
door of the storage facility to go through the files.
Petitioner husband attempted to establish the value of the
house by testifying that certain bids, ranging from $200,000 to
$245,000, were received to replace the house. The only
documentary evidence offered in support of this testimony,
however, was a brief prepared by petitioners in connection with
an Alabama State court proceeding in 2002. Petitioners otherwise
submitted no documentary evidence to show that such bids were
ever received or that any appraisal was ever made. Petitioner
husband’s self-serving statements in this proceeding and
petitioners’ statements in briefs purportedly filed in other
court proceedings are insufficient to establish the property’s
reduction in fair market value. See Ganas v. Commissioner, T.C.
Memo. 1990-143, affd. without published opinion 943 F.2d 1317
(11th Cir. 1991); Marcus v. Commissioner, T.C. Memo. 1988-3.
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