SWAN, Circuit Judge (after stating the facts as above).
The petitioner claims to be entitled to deduct from gross income for each taxable year in question its accrued but unpaid losses during the year on policies of liability insurance and workmen's compensation insurance. Its claim is based upon section 234(a) of the Revenue Act of 1918 (40 Stat. 1057, 1077), which reads, so far as material, as follows:
"Sec. 234(a) That in computing the net income of a corporation...
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