MILTON BRADLEY CO. v. UNITED STATES

No. 4031.

146 F.2d 541 (1944)

MILTON BRADLEY CO. v. UNITED STATES.

Circuit Court of Appeals, First Circuit.

December 22, 1944.


Attorney(s) appearing for the Case

Thomas V. Moriarty and Ralph W. Crowell, both of Springfield, Mass., for appellant.

John F. Costelloe, of Washington, D. C., A. F. Prescott and Mamie S. Price, Sp. Assts. to the Atty. Gen., Edmund J. Brandon, U. S. Atty., and George F. Garrity, Asst. U. S. Atty., both of Boston, Mass., Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key, Sp. Asst. to the Atty. Gen., for appellee.

Before MAGRUDER, MAHONEY, and WOODBURY, Circuit Judges.


MAHONEY, Circuit Judge.

This case presents the question whether a claim for refund of excise taxes which has been barred by the statute of limitations is deductible as a bad debt or loss in the computation of net income in the year in which the statute ran.

The taxpayer, Milton Bradley Company, is a Massachusetts corporation engaged in the manufacture of jigsaw puzzles. Under Section 609 of the Revenue Act of 1932, 47 Stat. 169, 26 U.S.C.A. Int.Rev.Acts, page...

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