SIBLEY, Circuit Judge.
Ensley Bank & Trust Company, as taxpayer, made income tax returns on the actual receipts and disbursements basis, claiming in 1933 and 1934 deductions on account of a partial charge-off in each year as worthless of a note due by the defunct Ensley National Bank for an original principal of $355,080.63. The deductions were disallowed, additional taxes were assessed and paid, refund denied, and suit brought in the District Court to recover...
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