Memorandum Findings of Fact and Opinion
COHEN, Judge.
Respondent determined a deficiency of $10,743 and additions to tax under sections 6651(a) and 6654 of $2,283.50 and $589.11, respectively, in petitioner's Federal income tax for 1990.
The issues for decision are whether petitioner is entitled to a theft loss deduction in 1990, stemming from amounts allegedly loaned by petitioner, and whether petitioner is liable for the additions to tax determined...
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