KIRKPATRICK, District Judge.
This is a suit to recover income and excess profits tax paid by the plaintiff, a national bank, for the year 1937. All relevant facts have been stipulated.
For the years 1931 to 1936 inclusive, the plaintiff charged off bad debts in large amounts and took corresponding deductions in its tax returns. In each year the deductions were greatly in excess of the net income and there was a deficit after the charge-off, the total of such...
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