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BERARDO v. COMMISSIONER

Docket No. 21022-85.

54 T.C.M. 344 (1987)

T.C. Memo. 1987-433

Michael J. Berardo and Annamaria Berardo v. Commissioner.

United States Tax Court.

Filed August 27, 1987.

Attorney(s) appearing for the Case

Barry A. Furman and Alan M. Bredt, 1845 Walnut St., Philadelphia, Pa., for the petitioners. Alan E. Cobb, for the respondent.

Memorandum Findings of Fact and Opinion

WELLS, Judge:

Respondent determined a deficiency in petitioners' individual income tax for 1978 in the amount of $51,913 and an addition to the tax under section 6653(a)1 in the amount of $2,596. The issues for decision are (1) whether petitioners have sustained a theft loss in 1978 and, if so, the amount of any such theft loss; (2) whether a $60,000 payment received by petitioners in 1978...

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