The Commissioner determined deficiencies in income tax for the years 1949, 1950, and 1951, in the amounts of $8,026.83, $2,620.72, and $807.27, respectively. The question presented is whether petitioner, a national banking corporation, is entitled to additions to its reserves for bad debts in the taxable years, and deduction therefor in each year. The Commissioner disallowed deduction in each year of all of the annual addition to its reserve for bad debts on the ground that...
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