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accrued action actually additional allowed amount annual Appeals applied assessed assets association authority bank bonds building capital carrying Cent Circuit claim collected collector Commissioner Comp Congress constitute construction contract corporation court decision deduction defendant determined distribution District dividends earnings effect engaged error excise tax existence expenses fact follows funds gross income held imposed interest Internal Revenue issued Judge judgment June land lease lessee lessor liability loan losses March meaning necessary operation opinion organized paid parties payment person plaintiff premiums present prior profits purchase question railroad Railway reason receipts received recover referred represented reserve respect rule securities shares Stat statute stockholders suit surplus thereof tion trust United York