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FMC CORPORATION AND SUBSIDIARIES v. COMMISSIONER

Docket No. 2317-00.

82 T.C.M. 884 (2001)

T.C. Memo. 2001-298

FMC Corporation and Subsidiaries v. Commissioner.

United States Tax Court.

Filed November 8, 2001.

Attorney(s) appearing for the Case

F. Brook Voght and David B. Blair, for the petitioner. Lawrence C. Letkewicz, for the respondent.

MEMORANDUM OPINION

LARO, Judge:

Petitioner petitioned the Court to redetermine respondent's determination of a $2,030,589 deficiency in its 1994 Federal income tax. Petitioner's sole assignment of error concerns respondent's disallowance of a $217,649,340 theft loss deduction claimed for that year. Petitioner alleged in its petition that the theft loss related to the fraudulent and illegal activities of Ivan F. Boesky (Boesky), which caused petitioner to...

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