WILBUR, Circuit Judge.
This is a petition to review the action of the Board of Tax Appeals sustaining the decision of the Commissioner of Internal Revenue disallowing certain deductions from gross income claimed by the petitioner by reason of bad debts amounting to $76,825. The amount of tax involved is $8,300.63 for the year 1929. It is conceded that the debts involved were worthless, and if the debts belonged to the petitioner it was entitled to the deduction claimed...
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