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MALDEN TRUST CO. v. COMMISSIONER OF INTERNAL REVENUE

No. 3480.

110 F.2d 751 (1940)

MALDEN TRUST CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, First Circuit.

March 29, 1940.

Attorney(s) appearing for the Case

Charles M. Rogerson, of Boston, Mass. (Howard C. Connor and Roger W. Hardy, both of Boston, Mass., on the brief), for petitioners for review.

Ugo Carusi, Sp. Asst. to Atty. Gen. (Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key, Sp. Asst. to Atty. Gen., on the brief), for Commissioner of Internal Revenue.

Before WILSON and MAGRUDER, Circuit Judges, and BREWSTER, District Judge.

BREWSTER, District Judge.

This is a petition to review a decision of the Board of Tax Appeals (39 B.T.A. 190) upholding the Commissioner's determination of a deficiency of $6,460.71 in the petitioner's income tax liability for the year 1933. The taxpayer claims to be entitled to (1) a bad debt deduction on certain promissory notes in the amount of $53,517.75; and (2) a loss deduction, arising from the foreclosure sales of certain properties at prices less than the...

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