Memorandum Findings of Fact and Opinion
WILBUR, Judge:
Respondent determined a deficiency in the Federal income tax of petitioner Sanford A. Berman of $5,886 for the year 1975. The issues for our decision are (1) whether petitioner is entitled to deduct the amount of money he invested in shares of now worthless stock as a theft loss under section 165(c)(3);
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