MEMORANDUM OPINION
DECKER, District Judge.
This is an action arising under 28 U.S.C. § 1346(a) (1) for recovery of federal income taxes alleged to have been illegally assessed and collected. Plaintiff is a Delaware corporation engaged primarily in the construction of gas distribution facilities. At issue is the disallowance by the District Director of Internal Revenue of a "bad debt" deduction claimed by plaintiff in its federal income tax return for...
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