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COMMISSIONER OF INTERNAL REV. v. LIBERTY BANK & TRUST CO.

Nos. 5780, 5867.

59 F.2d 320 (1932)

COMMISSIONER OF INTERNAL REVENUE v. LIBERTY BANK & TRUST CO. LIBERTY BANK & TRUST CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Sixth Circuit.

May 12, 1932.

Attorney(s) appearing for the Case

G. A. Youngquist, Ass't Atty. Gen. (Sewall Key, Hayner N. Larson, C. M. Charest, and Prew Savoy, all of Washington, D. C.), for Commissioner.

George M. Morris, of Washington, D. C. (KixMiller, Baar & Morris, of Washington, D. C., on the brief), for Liberty Bank.

W. A. Sutherland, of Atlanta, Ga., amicus curiæ.

Before MOORMAN, HICKS and HICKENLOOPER, Circuit Judges.

MOORMAN, Circuit Judge.

Petitions to review decisions of the Board of Tax Appeals by the taxpayer, the Liberty Bank & Trust Company, in No. 5867, and by the Commissioner in No. 5780.

The petitioner in No. 5867 contends that debts owing to it by the Kentucky Wagon Manufacturing Company and the Wolke Lead Batteries Company were recoverable only in part on December 31, 1921, and that deductions should have been allowed therefor from gross income for the year...

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