MATHEWS, Circuit Judge.
In his income tax return for 1927, petitioner claimed a deduction for bad debts in the amount of $34,404.74. The debts in question were represented by promissory notes owned and held by petitioner. Respondent, the Commissioner of Internal Revenue, disallowed the deduction and, in consequence of such disallowance, determined that there was a deficiency of $3,656.39 in respect of petitioner's income tax for 1927, and so notified petitioner, who...
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