ENGEL v. COMMISSIONER

Docket No. 4377-69.

31 T.C.M. 1223 (1972)

T.C. Memo. 1972-246

Max P. Engel and Lillian Engel v. Commissioner.

United States Tax Court.

Filed December 18, 1972.


Attorney(s) appearing for the Case

Sidney A. Soltz, Biscayne Bldg., Miami, Fla., for the petitioners. Clarence F. Frazier, Jr., for the respondent.


Memorandum Opinion

HALL, Judge:

The respondent determined a $3,615.78 deficiency in petitioners' 1966 Federal income tax. The sole issue for decision is whether petitioners are entitled to a deduction in 1966 for a theft loss in excess of the amount of their insurance recovery.

The parties have filed a stipulation of facts which, together with accompanying exhibits, is incorporated herein by this reference.

Petitioners, husband and wife,...

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