FRANK, Circuit Judge.
1. The taxpayer had at all times, until it came before us, taken an all-or-nothing attitude toward the allowance of the claimed deduction. At no time did it suggest to the Commissioner that if 100% of the debt was not deductible, some smaller portion should be allowed as a deduction. Nor did it request the Board to determine whether there was partial worthlessness. We think that it is now too late to ask for such a determination. For the Commissioner...
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