MEMORANDUM OPINION AND ORDER
WELLFORD, District Judge.
Plaintiff is in the marine towing business. One of its barges was damaged in a collision in June, 1972. Although damage to the barge was covered by insurance, plaintiff did not file a claim under its insurance policy but paid for the repairs to the barge itself and deducted the costs of the repairs on its income tax return for the year ending June 30, 1973. The Commissioner of Internal Revenue disallowed...
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