Respondent determined deficiencies in petitioner's declared value excess profits tax and excess profits tax for the year ended April 30, 1944, in the respective amounts of $450.51 and $17,126.90. The question is whether certain so-called debenture preferred stock issued by petitioner was stock or bonds, that is to say, whether it represented proprietary or creditor interests. Petitioner's principal office was in Wilmington, Delaware, and its returns were filed with the collector...
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