The respondent determined deficiencies in the income tax of petitioner in the amount of $6,368.47 for the year 1950 and $6,706.54 for the year 1951. The parties have settled several issues by agreement. The only issue for decision is whether all or only a portion of amounts totaling $900,000, which the petitioner borrowed from an insurance company in 1951, should be considered as borrowed capital in the computation of its excess profits credit for that year, based upon invested...
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