MULRONEY, Judge:
This opinion supersedes a previous opinion filed September 29, 1961, and withdrawn December 7, 1961.
The respondent determined a deficiency in petitioners' income tax for the year 1956 of $12,276.45. The question for decision is whether $25,000 paid for 10,000 shares of common stock issued by Pan Protective Life Insurance Co., Inc., is deductible as a theft loss in 1956.
FINDINGS OF FACT.
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