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SCHNEIDER v. COMMISSIONER

Docket No. 10998-76.

38 T.C.M. 1290 (1979)

T.C. Memo. 1979-335

Noland H. Schneider v. Commissioner.

United States Tax Court.

Filed August 23, 1979.

Attorney(s) appearing for the Case

John M. Bradley and David S. Geldzahler, for the petitioner.

Thomas N. Thompson and Charles H. Cowley, for the respondent.

Memorandum Findings of Fact and Opinion

FAY, Judge:

Respondent determined a deficiency of $31,500 in petitioner's 1972 Federal income tax. The sole issue presented is whether petitioner sustained a $50,000 theft loss within the meaning of section 165(c) (3)1 during 1972.

Findings of Fact

Some of the facts have been stipulated and are found accordingly.

At the time of filing his petition herein, petitioner...

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