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CHATHAM PHENIX NAT. BANK & TRUST CO. v. HELVERING

No. 6472.

87 F.2d 547 (1936)

CHATHAM PHENIX NAT. BANK & TRUST CO. v. HELVERING, Commissioner of Internal Revenue.

United States Court of Appeals for the District of Columbia.

Decided November 30, 1936.

Attorney(s) appearing for the Case

Albert A. Jones, of Washington, D. C., and Basil Robillard, of New York City, for petitioner.

Frank J. Wideman, Sewall Key, Robert H. Jackson, Harold Allen, J. Louis Monarch, Norman D. Keller, S. Dee Hanson, and Warner W. Gardner, all of Washington, D. C., for respondent.

Before ROBB, VAN ORSDEL, GRONER, and STEPHENS, JJ.

VAN ORSDEL, J.

This case is here for review of a decision of the United States Board of Tax Appeals.

The petitioner, a national bank (hereinafter referred to as the taxpayer), paid an income tax of $390,919.22 for the year 1930, after deducting the sum of $349,577.19 for bad debts. In 1932 the taxpayer filed an amended return for the year 1930, claiming a total deduction of $2,698,925.15 for bad debts, and filed a claim for refund of $282,-

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