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PAINE v. COMMISSIONER

Docket No. 2461-71.

63 T.C. 736 (1975)

LESTER I. PAINE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 31, 1975.

Attorney(s) appearing for the Case

Ralph Freedson, for the petitioner.

James N. Mullen, for the respondent.

OPINION

WILBUR, Judge:

Respondent has determined a deficiency of $19,371 in petitioner's 1966 Federal income tax. The sole issue presented is whether the petitioner incurred a theft loss within the meaning of section 165(c)(3)1 in 1966.

All the facts have been stipulated and the stipulation of facts, together with the exhibits attached thereto, are found accordingly.

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