MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
The issues for decision are whether petitioner is entitled to a theft loss deduction and whether respondent abused his discretion in proceeding with collection.
FINDINGS OF FACT
In 2000, petitioner was in an automobile accident, sustained serious injuries, and was in a coma for 45 days. Petitioner untimely filed his Federal income tax returns relating to 1996, 1997, 1998, 1999, and 2001...
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