OPINION
COHEN, Judge:
Respondent determined deficiencies of $33,723, $97,366, $86,233, and $739 in petitioner's Federal income tax for taxable years ended March 31 of 1979, 1980, 1981, and 1983, respectively. The issue for decision is whether for purposes of the personal holding company tax imposed by section 541 theft losses are deductible only in the year of discovery by the taxpayer. Unless otherwise indicated, all section references are to the...
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