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CAPALBO v. COMMISSIONER

Docket No. 7243-76.

36 T.C.M. 1671 (1977)

T.C. Memo. 1977-412

Paul J. Capalbo and Cynthia C. Capalbo v. Commissioner.

United States Tax Court.

Filed November 30, 1977.

Attorney(s) appearing for the Case

Herbert P. Phillips, 25 Kenoza Ave., Haverhill, Mass., for the petitioners. W. Terrence Mooney, for the respondent.

Memorandum Findings of Fact and Opinion

FEATHERSTON, Judge:

Respondent determined a deficiency in the amount of $4,993.36 in petitioners' Federal income tax for 1974. The only issue for decision is whether petitioners have established the accumulation and subsequent theft of $20,000 cash hoard so as to be entitled to a theft loss deduction under section 165.1

Findings of Fact

Petitioners Paul J. Capalbo and...

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