MEMORANDUM OPINION
TANNENWALD, Judge:
Respondent determined a deficiency in petitioner's Federal income tax in the amount of $94,759 for the taxable year 1992. The issues for decision are:
(1) Whether petitioner is entitled to a loss deduction for money forfeited to the United States;
(2) if not, whether imposing a liability for taxes on forfeited money without allowing a loss deduction violates the ;Double Jeopardy Clause of the Fifth Amendment...
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