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Respondent determined a deficiency in petitioner’s Federal
income tax for 2000 in the amount of $13,801. The sole issue for
decision is whether petitioner is entitled to a theft loss
deduction under section 165(a) of $202,830 with respect to his
investment in the stock of Ampex Corp. (Ampex).
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts, the supplemental stipulation of facts,
and the attached exhibits are incorporated herein by this
reference. At the time of filing the petition, petitioner
resided at Culver City, California.
Petitioner is a certified public accountant. Since 1981,
his practice has involved financial audits of publicly held
corporations, income tax return preparation for individuals and
business entities, and tax audit representation.
In October 1999, petitioner received a positive
recommendation on Ampex from a securities broker. Ampex is a
publicly traded corporation, and during the period in question it
was listed on the American Stock Exchange under the symbol
“AXC”.1 Ampex is a provider of technologies for the acquisition,
storage, and processing of visual information. During 1999, a
1 Ampex’s Class A common shares were traded on the American
Stock Exchange from Jan. 16, 1996, until Nov. 21, 2003, when
Ampex was delisted for failure to meet the minimum stockholders’
equity requirement. Subsequently, its Class A common shares were
listed for quotation on the OTC Bulletin Board, an interdealer,
over-the-counter market.
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