SETH, Circuit Judge.
Income tax deficiencies were assessed against petitioner by reason of a deduction taken in 1958 in the amount of $139,200.00 for uncollectible notes held by the petitioner. The notes were given to the corporation in 1933 by a former officer who, in 1927, 1928, and 1929, had embezzled approximately $367,309.52 from the taxpayer-corporation. The taxpayer had previously taken deductions for the total amount of the embezzlement in the three years...
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