KERNER, Circuit Judge.
This is a petition for the review of a decision of the Board of Tax Appeals approving the action of the respondent, who found that petitioner was liable for a deficiency income tax for the year 1936 resulting from the disallowance of a deduction of $3,500 claimed to be a bad debt, ascertained to be worthless and charged off during the taxable year.
By § 23 of the Revenue Act of 1936, c. 690, 49 Stat. 1648, 1660, 26 U.S.C.A.Int....
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