DIETRICH, Circuit Judge.
On December 31, 1920, the American National Bank of San Francisco, hereinafter referred to as the petitioner, charged off on its books, and later in its income tax return for that year deducted from gross income, the sum of $68,538.41 as a bad debt. Disallowing the deduction, the Commissioner assessed an additional tax of $18,410.72. Petitioner appealed to the Board of Tax Appeals, and, failing to get relief, it comes here upon a petition...
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