OPINION.
MULRONEY, Judge:
The respondent determined deficiencies in petitioners' income tax for the years 1955 and 1956 in the respective amounts of $535.39 and $1,972.31.
The only issue presented is whether the 1956 payment by Harry Horner of a judgment, court costs, and appellate expense in the sum of $6,255.10 is deductible in that year as a loss under section 165, I.R.C. 1954,
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