LITTLETON, Judge.
This case involves an alleged tax overpayment of $72,219.68, for 1918, by reason of the disallowance by the Commissioner of a deduction from gross income of $80,410.21 determined to be worthless and charged off by plaintiff in 1918. This alleged debt from Brown and Munsell to plaintiff arose and accrued between May, 1898, and December, 1905, under a certain contract between Brown and Munsell and plaintiff's predecessor, the Diamond Drill & Machine...
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