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BEAVER v. COMMISSIONER

Docket No. 10305-01.

85 T.C.M. 1265 (2003)

T.C. Memo. 2003-129

Rudolph H. Beaver v. Commissioner.

United States Tax Court.

Filed May 2, 2003.

Attorney(s) appearing for the Case

John F. Lyle III, Gwen D. Skinner, and Mark M. Gibson, for the petitioner.

Horace Crump, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

LARO, Judge:

Respondent determined deficiencies of $257,442, and $406,438 in petitioner's 1997 and 1998 Federal income taxes. We decide whether petitioner may deduct for 1997 any portion of a theft loss that he had previously deducted for 1993 as a capital loss. We hold he may not.1 Unless otherwise noted, section references are to the applicable versions of the Internal Revenue Code. Rule...

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