MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
Respondent determined a $19,026 deficiency in petitioners' 1993 Federal income tax. After concessions by petitioners, the issue for decision is whether petitioners are entitled to deduct a theft loss of $769,800. We hold they are to the extent provided below. Unless otherwise indicated, all section references are to the Internal Revenue Code for the year in issue, and all Rule references are to the Tax...
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