MANSFIELD v. COMMISSIONER

Memorandum Findings of Fact and Opinion

CLAPP, Judge:

By statutory notice of deficiency, respondent determined that petitioner misappropriated $372,468 in 1983 from his employer, of which amount, $261,677 had been repaid. Respondent increased petitioner's 1983 taxable income by $110,791 ($372,468 — $261,677) and determined a deficiency in and additions to petitioner's 1983 tax as follows:

                                    Additions...

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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