T.C. Memo. 1998-58
UNITED STATES TAX COURT
RUSSELL W. AND REBECCA A. WILLEY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 27751-96. Filed February 11, 1998.
Russell W. and Rebecca A. Willey, pro sese.
Ruth M. Spadaro, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge: Respondent determined a $19,026 deficiency in
petitioners' 1993 Federal income tax. After concessions by
petitioners, the issue for decision is whether petitioners are
entitled to deduct a theft loss of $769,800. We hold they are to
the extent provided below. Unless otherwise indicated, all
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