Esther owns a large home on the East Coast. Her home is surrounded by large, mature oak trees that significantly increase the value of her home. In August 2015, a hurricane damaged many of the trees surrounding her home. In September 2015, Esther engaged a local arborist to evaluate and treat the trees, but five of the largest trees were seriously weakened by the storm. These trees died from disease in 2016. Esther has ascertained that the amount of the casualty loss from the death of the five trees is $25,000; however, she is uncertain in which year to deduct this loss. Discuss whether the casualty loss should be deducted in the calculation of Esther's 2015 or 2016 taxable income.
Partials list of research aids:
Reg. § 1.165-1.
Oregon Mesabi Corporation, 39 B.T.A. 1033 (1939).