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DADE-COMMONWEALTH TITLE COMPANY v. COMMISSIONER

Docket No. 4932.

6 T.C. 332 (1946)

DADE-COMMONWEALTH TITLE COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated March 5, 1946.

Attorney(s) appearing for the Case

Douglas D. Felix, Esq., for the petitioner.

F. L. Van Haaften, Esq., for the respondent.

This proceeding involves income tax deficiencies of $288.61 and $689.60 for the fiscal years ended February 28, 1941, and February 28, 1942, respectively. The only question in issue is whether petitioner is entitled to deduct the full amount of the interest which it paid on its outstanding debentures during the taxable years.

The parties have submitted a written stipulation of facts and have further stipulated that all of the...

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