CHASE, Circuit Judge.
The petitioner took a deduction in his income tax return for 1936 for a bad debt determined to be worthless and charged off in that year, and claimed deductible under the provisions of § 23(k) of the Revenue Act of 1936, 26 U.S.C.A. Int.Rev.Acts, page 828. The commissioner disallowed it and determined a deficiency. The tax court upheld this determination upon finding that "the petitioner must have known long prior to 1936 that his debt was...
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