Bennett v. Commissioner of Internal Revenue

HUTCHESON, Circuit Judge.

This appeal is from a decision and order of the Board, 1 denying the petition of Bennett and his wife, to redetermine deficiencies. It presents two questions for decision: (1) Is the judgment of the District Court of the United States, that Bennett was liable on his endorsement in 1930, of certain notes to Standard Trust Company as trustee, and that he could take a bad debt deduction when he took one of them up in 1934, res judicata, as to those he took up in 1935 under the same circumstances? (2) If not, was the District Court right in holding that he was, or the…