Part III -- Administrative, Procedural, and Miscellaneous
Loss Deductions for Diminution in Value of Stock Attributable to Corporate Misconduct
Notice 2004-27
The Internal Revenue Service and Treasury Department are aware that some taxpayers who acquired stock on the open market for investment have been advised that they may be able to deduct as a theft loss the decline in market value of their stock caused by disclosure of accounting fraud or other illegal misconduct of the officers or directors of the corporation that issued the stock. The purpose of this notice is to advise taxpayers that the Service intends to disallow such deductions and may impose penalties under section 6662.