Research Problem 3. Jeb Simmons operated an illegal gambling business out of his home.

While executing a search warrant, the local sheriff seized gambling paraphernalia and

$200,000 in cash. Subsequently, Jeb voluntarily consented to forfeit to the state the cash that had been seized in connection with the execution of the search warrant. Write a letter to Jeb advising him as to whether he can claim a loss under § 165 for the seized cash.

Also prepare a memo for the tax files. Jeb’s address is 100 Honey Lane, Macon, GA 31208.