HOLLOWAY, Circuit Judge.
Plaintiff-appellee J.B.N. Telephone Co., Inc. (J.B.N.) claimed a deduction on its 1972 federal income tax return for a loss resulting from the abandonment of obsolete telephone equipment. The Internal Revenue Service disallowed the deduction and issued a notice of deficiency on the ground that J.B.N. simultaneously acquired and abandoned the equipment and therefore had no basis in it. J.B.N. paid the deficiency, filed a refund claim, which...
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