Memorandum Findings of Fact and Opinion
STERRETT, Judge:
By statutory notice dated October 8, 1976, respondent determined a deficiency of $6,393 in petitioners' Federal income tax for the taxable year ended December 31, 1973. After concessions, the sole issue remaining for our decision is whether petitioners are entitled to a theft loss deduction, pursuant to section 165, I.R.C. 1954, in the amount of $16,100 resulting from Mr. Kloosterhouse's payments to...
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