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HARDING v. UNITED STATES

No. 50457.

113 F.Supp. 461 (1953)

HARDING v. UNITED STATES.

United States Court of Claims.

July 13, 1953.

Attorney(s) appearing for the Case

Daniel M. Gribbon, Washington, D. C., for plaintiff. Dean P. Kimball and Covington & Burling, Washington, D. C., were on the briefs.

Elizabeth B. Davis, Washington, D. C., with whom was Asst. Atty. Gen. H. Brian Holland, for defendant. Ellis N. Slack and Andrew D. Sharpe, Washington, D. C., were on the brief.

WHITAKER, Judge.

This is a suit to recover income taxes for the years 1944 and 1945. Plaintiff is entitled to recover if he is entitled to carry back to those years a loss sustained by him in 1946 due to the charging off in that year of a bad debt in the sum of $345,746.28. He is entitled to do so if it was a loss "attributable to the operation of a trade or business regularly carried on by the taxpayer."

This indebtedness, which turned out to be a bad debt...

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