Memorandum Findings of Fact and Opinion
PARR, Judge:
Respondent determined a $10,937 deficiency in petitioner's Federal income tax for calendar year 1982 based upon the disallowance of a theft loss deduction.
Petitioner claimed a $77,800 theft loss deduction on her 1982 Federal income tax return for the following:
(a) Cash ..................... $ 4,500 (b) Cash (Deeds of Trust) .... 61,000 (c) Jewelry ................
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