Jackson Jumper has owned a beach house for the last 20 years. In 2018, a hurricane destroyed his beach house and the beach was determined to be a federally declared disaster area. His adjusted basis in the house was $200,000 but the FMV was $270,000 because of the resort areas developing around his property. The house was insured for only $170,000. What is Jackson's casualty and theft loss for the year assuming a $100,000 adjusted gross income?