HOLMES, Circuit Judge.
The appellant, First National Bank in Houston, brought this action against the appellee, Collector of Internal Revenue, to recover allegedly excessive income taxes paid for the year 1944. The appellant, hereinafter referred to as the taxpayer, was organized and began business in 1933. During the years 1931 to 1935, the taxpayer's predecessor, First National Bank of Houston, charged off as worthless bad debts certain securities...
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