James Petroleum Corporation v. Commissioner of Internal Revenue

SETH, Circuit Judge.

Income tax deficiencies were assessed' against petitioner by reason of a deduction taken in 1958 in the amount of $139,-200.00 for uncollectible notes held by the-petitioner. The notes were given to the corporation in 1933 by a former officer who, in 1927, 1928, and 1929, had embezzled approximately $367,309.52 from the taxpayer-corporation. The taxpayer had' previously taken deductions for the total' amount of the embezzlement in the three-years when the embezzlements took place. Each deduction was in the amount embezzled in each year, 1927, $44,291.88; 1928, $219,751.94;…