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FOWLER BROS. & COX v. COM'R OF INTERNAL REVENUE

No. 9459.

138 F.2d 774 (1943)

FOWLER BROS. & COX, Inc., v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Sixth Circuit.

November 29, 1943.

Attorney(s) appearing for the Case

Scott P. Crampton, of Washington, D. C. (Geo. E. H. Goodner and Scott P. Crampton, all of Washington, D. C., on the brief), for petitioner.

Newton K. Fox, of Washington, D. C. (Samuel O. Clark, Jr., Sewall Key, Helen R. Carloss, and William A. Clineburg, all of Washington, D. C., on the brief), for respondent.

Before HICKS, HAMILTON, and McALLISTER, Circuit Judges.

McALLISTER, Circuit Judge.

Petitioner appeals from the decision of the Board of Tax Appeals (now the Tax Court of the United States), which denied deductions claimed on income tax return for a bad debt, payment of salaries, and dividends.

Deduction for Bad Debt

The alleged worthless debt consisted of a deposit in a closed bank; but petitioner owed to the bank, on promissory note, at least as much as the deposit. Petitioner for several years was attempting...

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