HULEN, District Judge.
Plaintiff brings this action to recover a deficiency assessment made against him by the Commissioner of Internal Revenue for income taxes for the year 1937 of $14,962.67, with interest from June 20, 1940, the date of payment of the deficiency. The alleged error of the Commissioner in asserting the deficiency is based on the following facts:
On January 5, 1929, plaintiff loaned Lindell Gordon, Jr., $32,000, on a collateral note secured...
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