Russell W. and Rebecca A. Willey - Page 1

                                 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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