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SOBHANI v. COMMISSIONER

Docket No. 45048-86.

59 T.C.M. 181 (1990)

T.C. Memo. 1990-150

Mohi Sobhani and Farnaz Sobhani v. Commissioner.

United States Tax Court.

Filed March 20, 1990.

Attorney(s) appearing for the Case

William J. Ferrin, 5959 Topanga Canyon Blvd., Woodland, Calif., for the petitioners. Jeffrey A. Sherman, for the respondent.

Memorandum Findings of Fact and Opinion

WRIGHT, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for 1982 in the amount of $1,685, and an addition to tax under section 6651(a)(1)1 in the amount of $194.40.

The issues for decision are: (1) whether petitioners are entitled to a loss deduction under section 165 for taxable year 1982 due to the theft of gold coins and jewelry; and (2) whether petitioners...

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