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JOHN W. WALTER, INC. v. COMMISSIONER

Docket No. 44002.

23 T.C. 550 (1954)

JOHN W. WALTER, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 30, 1954.

Attorney(s) appearing for the Case

Benjamin Alpert, Esq., for the petitioner.

Arthur L. Nims, Esq., for the respondent.

Respondent determined deficiencies in petitioner's income taxes for the years 1946, 1947, and 1948 in the amounts of $2,242.10, $2,496.29, and $1,223.72, respectively. The question to be decided is whether certain securities issued by petitioner to its sole stockholder in 1946 were valid debenture bonds and represented an indebtedness permitting the deduction of alleged interest payments thereon under section 23 (b) of the Internal Revenue Code of 1939.

FINDINGS...

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