Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined a $39,081.90 deficiency in petitioner's 1975 Federal income tax.
After concessions, the issues for decision are: (1) Whether petitioner incurred a $70,000 theft loss during 1975 for funds allegedly stolen from him by his former wife, or in the alternative whether petitioner may claim the $70,000 amount as an alimony deduction pursuant to section 215;
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