NATIONAL BANK OF COMMERCE v. COMMISSIONER OF INT. REV.

No. 9426.

115 F.2d 875 (1940)

NATIONAL BANK OF COMMERCE OF SEATTLE v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Ninth Circuit.

Rehearing Denied December 31, 1940.


Attorney(s) appearing for the Case

Thomas N. Fowler, of Seattle, Wash., for petitioner.

Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key, Michael H. Cardozo, IV, and Lee A. Jackson, Sp. Assts. to the Atty. Gen., for respondent.

Before GARRECHT, HANEY, and HEALY, Circuit Judges.


HANEY, Circuit Judge.

We have been petitioned to review a decision of the Board of Tax Appeals to the effect that certain recoveries on doubtful debts should have been reported as income, and that a deduction for bad debts was improper.

Marine Bancorporation owned about 90 percent of the stock of petitioner and of six smaller banks. In 1933, each of the six smaller banks charged off its books certain debts considered to be worthless or subject to criticism...

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