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CROWELL v. COMMISSIONER

Docket No. 2659-82.

51 T.C.M. 1556 (1986)

T.C. Memo. 1986-314

Donald W. Crowell and Suzanne C. Crowell v. Commissioner.

United States Tax Court.

Filed July 28, 1986.

Attorney(s) appearing for the Case

William R. Nicholas and Boyd J. Black, for the petitioners. Charles W. Jeglikowski and David P. Fuller, for the respondent.

Memorandum Opinion

CLAPP, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for the year 1973 in the amount of $28,268.19. The sole issue for decision is whether petitioners are entitled to a theft loss deduction under section 165(c)(3)1 with respect to their investment in the stock of Equity Funding Corporation of America (EFCA).

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