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ANDERSON v. COMMISSIONER OF INTERNAL REVENUE

No. 204, Docket 20098.

156 F.2d 591 (1946)

ANDERSON v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Second Circuit.

July 15, 1946.

Attorney(s) appearing for the Case

J. F. Collins and Nelson Gammans, both of New York City, for petitioner.

Sewall Key, of Washington, D.C. (Helen R. Carloss and Hilbert P. Zarky, both of Washington, D.C., of counsel), for respondent.

Before SWAN, CLARK, and FRANK, Circuit Judges.

FRANK, Circuit Judge.

The findings, legal conclusions and opinion of the Tax Court are reported in 5 T.C. 482. The evidence sufficiently supports the findings. We agree with that court's interpretation of the partnership agreement in the light of the findings. It follows that the decision was correct, i.e., that when the debt from King became worthless, it was not owing to taxpayer. He, or...

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