Memorandum Findings of Fact and Opinion
WILBUR, Judge:
Respondent determined a deficiency of $2,406 in petitioner's 1975 Federal income tax. The sole issue before us is whether or not petitioner sustained a theft loss pursuant to section 165(c).
Findings of Fact
The parties have submitted a stipulation of facts which, together with the exhibits attached thereto, are incorporated herein by this reference.
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