OPINION.
SMITH, Judge:
This proceeding is for the redetermination of a deficiency in income tax for the calendar year 1938 in the amount of $291.71.
In its income tax return for the calendar year 1938 the petitioner claimed the deduction from gross income of $5,955.04 as interest paid to holders of debenture preferred stock. The deduction was disallowed by the respondent who held in his deficiency notice "that the payment does not represent...
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