McDERMOTT, Circuit Judge.
The plaintiff below, appellee here, recovered a judgment for $14,460.43 on account of an overpayment of income taxes for the year 1929, a claim for refund thereof having been denied. The question in dispute is whether the taxpayer was entitled to deduct from its income certain losses arising from the liquidation of two of its subsidiaries. The case was tried without a jury, and the facts specially found by the trial court.
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