- 6 -
Web page, revealed that the First American Discount Corporation
had withdrawn as a member of the Chicago Board of Trade. The
third document, also a copy of a Web page, indicated that
Kristian Capital Management either withdrew or had rescinded its
membership in the National Futures Association, an independent,
regulatory organization for the futures industry. Petitioner
provided no evidence, however, of his basis in the Kristian
Capital Management account, that embezzlement of his funds
occurred, or of the amount of his purported loss. Therefore, we
cannot conclude that a loss occurred. Accordingly, we hold that
petitioner is not entitled to a loss deduction attributable to
his brokerage account with Kristian Capital Management.
Employment With Wyeth-Aryst Pharmaceutical
Petitioner testified that he was dismissed from his
consulting job at Wyeth-Aryst Pharmaceutical because he was
“ethically opposed” to the work assigned to him, and that company
officials barred him from reentering his office to retrieve his
personal effects.
Section 165(a) provides a theft loss deduction in the
taxable year in which the taxpayer discovers the loss. The basis
for determining the amount of the deduction for any loss is the
lesser of the fair market value or the adjusted basis of the
property prescribed by section 1011. Secs. 1.165-7(b)(1), 1.165-
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011