Memorandum Findings of Fact and Opinion
SWIFT, Judge:
Respondent determined deficiencies in petitioners' Federal income tax for 1981 and 1982 in the respective amounts of $211,887.00 and $20,064.50. The issues remaining for decision are whether petitioner Diana D. Knowles (petitioner) is entitled to a theft loss deduction or, alternatively, to a long-term capital loss deduction with respect to her investment in a coal mining limited partnership. Respondent...
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