WISDOM, Circuit Judge.
This appeal turns on the tax effect of a deposit in escrow of funds as security for the execution of a supersedeas bond in order to perfect the taxpayer's appeal from an adverse judgment in a suit for personal injuries. The taxpayer contends that deposit in escrow is equivalent to payment of the judgment and that the amount of the judgment may be deducted by a taxpayer on an accrual basis in the year in which the deposit was made. The district...
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