Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined a deficiency in the Federal income tax of petitioners for the calendar year 1962 in the amount of $6,893.35.
This sole issue for determination is whether petitioners are entitled to deduct the amount of $19,000 as a theft loss, pursuant to section 165 of the Internal Revenue Code of 1954.
Findings of Fact
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