T.C. Memo. 2007-366
UNITED STATES TAX COURT
JAMES G. AND ELAINE A. WANCHEK, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17614-05. Filed December 11, 2007.
On their amended 2001 Federal income tax return, P’s
claimed a theft loss deduction of $172,904 on the basis that
their contractor had committed fraud against them. R
disallowed the entire theft loss deduction and determined a
deficiency.
Held: Ps are not entitled to any theft loss deduction
for the 2001 taxable year.
Paul A. Bleicher, for petitioners.
Vicki L. Miller, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
WHERRY, Judge: This case is before the Court on a petition
for redetermination of a deficiency of $10,255 that respondent
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