Respondent determined deficiencies in petitioner's excess profits tax for the years 1942 and 1943 of $92,176.50 and $31,126.75, respectively. Petitioner claims an overpayment for these years in the respective amounts of $77,895.06 and $125,728.85.
The issues presented are (1) whether certificates of deposit issued by petitioner are properly includible in its borrowed capital within the meaning of section 719 (a) (1) of the Internal Revenue Code; (2) whether, in computing...
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