RIET v. COMMISSIONER

Memorandum Findings of Fact and Opinion

PARR, Judge:

Respondent determined a $10,937 deficiency in petitioner's Federal income tax for calendar year 1982 based upon the disallowance of a theft loss deduction.

Petitioner claimed a $77,800 theft loss deduction on her 1982 Federal income tax return for the following:

    (a) Cash .....................   $ 4,500
    (b) Cash (Deeds of Trust) ....    61,000
    (c) Jewelry ................

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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