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PEERLESS OIL & GAS CO. v. HEINER

No. 5809.

81 F.2d 391 (1936)

PEERLESS OIL & GAS CO. v. HEINER, Collector of Internal Revenue.

Circuit Court of Appeals, Third Circuit.

Rehearing Denied February 19, 1936.

Attorney(s) appearing for the Case

E. B. Strassburger and Strassburger & McKenna, all of Pittsburgh, Pa., for appellant.

Frank J. Wideman, Asst. Atty. Gen., Sewall Key, Norman D. Keller, and S. E. Blackham, Sp. Assts. to the Atty. Gen., and Horatio S. Dumbauld, U. S. Atty., of Pittsburgh, Pa., for appellee.

Before BUFFINGTON, DAVIS, and THOMPSON, Circuit Judges.

BUFFINGTON, Circuit Judge.

The question in this case is whether the taxpayer, Peerless Oil Company, is entitled under section 234 (a) of the Revenue Act of 1926, 44 Stat. 41, to deduct certain debts for the taxable year of 1927 as worthless.

The taxpayer made to a corporation several large loans on real estate located in Florida. These loans were secured by second mortgages. After making loans totaling $318,000, the plaintiff was forced to purchase certain...

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