PACIFIC NAT. BANK v. COMMISSIONER OF INTERNAL REVENUE

No. 8276.

91 F.2d 103 (1937)

PACIFIC NAT. BANK OF SEATTLE v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Ninth Circuit.

June 21, 1937.


Attorney(s) appearing for the Case

Todd, Holman & Sprague, William M. Allen, and Emory E. Hess, all of Seattle, Wash., for petitioner.

Robert H. Jackson, Asst. U. S. Atty. Gen., and Sewall Key, L. Louis Monarch, Norman D. Keller, S. Dee Hanson, and Warren F. Wattles, Sp. Assts. to Atty. Gen., for respondent.

Before WILBUR and MATHEWS, Circuit Judges, and NETERER, District Judge.


MATHEWS, Circuit Judge.

In its income tax return for 1931, petitioner, the Pacific National Bank of Seattle, claimed a deduction of $11,209.08 on account of debts ascertained to be partially worthless and recoverable only in part and, for that reason, charged off in part within the taxable year. The debts in question were interest-bearing bonds owned and held by petitioner. Respondent, the Commissioner of Internal Revenue, disallowed the deduction and, in consequence...

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