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PRICE v. COMMISSIONER OF INTERNAL REVENUE

No. 4480.

106 F.2d 336 (1939)

PRICE v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fourth Circuit.

August 28, 1939.

Attorney(s) appearing for the Case

George D. Brabson, of Washington, D. C., and Julius C. Smith, of Greensboro, N. C. (C. R. Wharton, of Greens-boro, N. C., and D. H. Blair, of Washington, D. C., on the brief), for petitioner.

Berryman Green, Sp. Asst. to Atty. Gen. (Sewall Key, Sp. Asst. to Atty. Gen., on the brief), for respondent.

Before PARKER and NORTHCOTT, Circuit Judges, and H. H. WATKINS, District Judge.

PARKER, Circuit Judge.

This is a petition to review a decision of the Board of Tax Appeals, approving a deficiency assessment for the year 1932. The question involved relates to the deducibility of a loss which taxpayer claims to have sustained in that year on a contract of guaranty previously executed. The Board denied the deduction on the ground that taxpayer, who made his return on the cash receipts and disbursements basis, gave a note covering the loss and that...

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