Respondent determined deficiencies in excess profits tax for the calendar years 1944 and 1945 in the respective amounts of $8,377.85 and $11,319.76. The sole issue is whether or not borrowings by petitioner from three banks, evidenced by notes, and used by petitioner to buy United States Treasury bonds and notes, which were pledged to the banks as collateral to secure payment of the notes, constitute borrowed invested capital under section 719, Internal Revenue Code. Part...
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