DENMAN, Chief Judge.
The taxpayer, American Factors, Limited, appeals from a judgment of the United States District Court, District of Hawaii, rendered upon a complaint for a refund of taxes claimed to be overpaid for the tax year 1932. The complaint alleges that the Commissioner of Internal Revenue had erred in disallowing a deduction made in the taxpayer's return for that year of $568,607.76, as an ordinary and necessary business expense. This sum had been paid...
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