LITTLETON, Judge.
Plaintiffs filed a joint income tax return for the calendar year 1934. They sue to recover an alleged overpayment in tax of $7,654.38, with interest, for that year. A refund claim was filed and rejected. The question presented is whether the amount of $13,305.58, representing a portion of an amount of $45,000 advanced to plaintiff, Arthur H. Wells, under the circumstances set forth and described in the findings, was taxable income for 1934.
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