Memorandum Findings of Fact and Opinion
The Commissioner determined an income tax deficiency in the amount of $5,956.36 for the calendar year 1939, and petitioner claims an over-payment for the same year in the sum of $47.20. The issue is whether an indebtedness, for the purpose of a dividends paid credit, was paid in the tax year or, on the other hand, was merely renewed. The return of General Plastics, Inc. was filed in the 28th district of New York.
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