- 2 -
After concessions, the issues for decision are: (1) Whether
Mr. Brown is entitled to a loss deduction in the amount of
$30,900 for currency that was seized by Louisiana law enforcement
officials pursuant to a civil forfeiture statute; (2) whether Mr.
Brown is entitled to a Schedule E loss deduction in the amount of
$5,000 for a deposit he made on a townhouse; (3) whether Mr.
Brown is entitled to claim a deduction for a theft loss in the
amount of $22,300; and (4) whether Mr. Brown is liable for self-
employment taxes under the provisions of section 1401.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Mr. Brown resided in
Alexandria, Louisiana, at the time the petition was filed.
On September 28, 1993, Mr. Brown was arrested along with two
other individuals in Lake Charles, Louisiana. At the time of his
arrest, Mr. Brown was carrying $30,900 in currency. Law
enforcement officials confiscated the currency as suspected drug
money. On November 2, 1993, before the State of Louisiana had
instituted formal judicial forfeiture proceedings, Mr. Brown
1(...continued)
Practice and Procedure.
2On Mar. 18, 1996, respondent filed a report to the Court
conceding that Mr. Brown was not liable for the accuracy-related
penalty under sec. 6662(a).
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