The Commissioner determined deficiencies for 1945 of $46.81 in income tax, $9,531.81 in tax under section 102, and $3,690.32 in excess profits tax. The issues for decision are whether the petitioner is subject to tax under section 102 and whether funds borrowed by the petitioner qualify as borrowed invested capital under section 719.
FINDINGS OF FACT.
The petitioner, a New York corporation, filed its returns for 1945 with the collector of internal revenue...
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