The respondent has determined a deficiency of $538.05 in the petitioners' income tax for the calendar year 1945. The deficiency results from the disallowance of a deduction in the amount of $1,121.05 claimed as interest on an annuity. The petitioners while no longer contesting the disallowance of the interest item as such seek an overpayment on the basis that petitioner Donald H. Sheridan's annuity payments, which were applied against principal, exceeded the consideration...
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