The Commissioner determined a deficiency in petitioners' 1959 income tax in the amount of $1,222.96, as a result of his disallowance of a claimed casualty loss deduction in the amount of $5,752. The principal issue is whether a loss from dry rot in petitioners' home qualifies as a casualty loss under section 165(c)(3) of the 1954 Code; a subsidiary issue involves the amount of the loss.
FINDINGS OF FACT
Petitioners, husband and wife, are residents of Richmond...
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