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INDUSTRIAL TRUST CO. v. COMMISSIONER OF INTERNAL REV.

No. 4701.

206 F.2d 229 (1953)

INDUSTRIAL TRUST CO. v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals, First Circuit.

July 7, 1953.

Attorney(s) appearing for the Case

Stuart H. Tucker, Providence, R. I. (Hinckley, Allen, Salisbury & Parsons, Providence, R. I., on the brief), for petitioner.

Cecelia H. Goetz, Sp. Asst. to the Atty. Gen. (H. Brian Holland, Asst. Atty. Gen., and Ellis N. Slack and Helen Goodner Sp. Assts. to the Atty. Gen., on the brief), for respondent.

Before MAGRUDER, Chief Judge, and WOODBURY and HARTIGAN, Circuit Judges.

HARTIGAN, Circuit Judge.

This is a petition under 26 U.S.C. §§ 1141, 1142, for review of a decision by the Tax Court entered on June 18, 1952, determining a deficiency of $55,561.94 against the taxpayer for the year 1943, based on the disallowance of a claimed deduction of $324,698.41 for a secured debt contracted in 1929 which allegedly became totally worthless upon final liquidation of the collateral in 1943. The petitioner, Industrial Trust Company, a...

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