Appeal of Citizens Trust Co. of Utica

*1243OPINION.

James:

The taxpayer in its petition sets forth nine several and distinct allegations of error on the part of the Commissioner in the determination of the tax for the years 1919, 1920, and 1921. For the most part these errors deal with questions of fact, although in some instances the errors alleged present mixed questions of fact and law. They will be taken up in order as set forth in the findings, except as to the three transactions involving A. James Eckert, which will be considered together.

In the matter of the indebtedness of Sam Kappler the Commissioner admitted that a loss…