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legal expenditures that petitioner had paid as of the end of 1993
were for the recovery of the principal of the Miller loan, and
not for the recovery of interest thereunder. On the record
before us, we find that petitioner has failed to establish that
the unrecovered portion of the Miller loan and the legal expendi-
tures that he had paid as of the end of 1993 in connection with
the recovery of that loan constitute under section 165(c) a loss
that he incurred during 1993 (1) in a trade or business, (2) in a
transaction entered into for profit, even though not connected
with a trade or business, or (3) from fire, storm, shipwreck, or
other casualty, or from theft.
To reflect the foregoing and the concession of petitioner,
Decision will be entered
for respondent.
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