Memorandum Findings of Fact and Opinion
TRAIN, Judge:
The respondent determined a deficiency in petitioner's income tax for the year 1952 in the amount of $5,454.37. One issue has been settled by stipulation, to which effect will be given under Rule 50. The issues for decision are:
(1) Whether petitioner is entitled to deduct as a loss from theft pursuant to section 23(e) of the Internal Revenue Code of 1939 the amount of $10,972.85 or any portion...
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