The Commissioner determined a deficiency in income tax for the year 1946 in the amount of $16,769.38. Two issues are involved: (1) Whether certain payments by petitioner constituted interest payments which are deductible for income tax purposes or dividends which are not deductible, and (2) whether certain expenditures made by petitioner are deductible as ordinary and necessary business expenses or whether they constitute capital expenditures.
Some of the facts were...
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