MEMORANDUM OPINION AND ORDER
JOSEPH H. YOUNG, District Judge.
This action was instituted pursuant to 28 U.S.C. § 1346(a)(1) to recover taxes allegedly erroneously assessed and collected from the plaintiff. Plaintiff claims that she is entitled to a "theft loss" deduction, including attorney fees, incurred in connection with a theft loss under 26 U.S.C. § 165(a)(c)(3). The United States seeks summary judgment, asserting that the loss claimed was...
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