Memorandum Findings of Fact and Opinion
This proceeding involves the following deficiencies in income tax:
Income Tax Year Deficiency 1951 ........ $ 557.02 1952 ........ 563.25 1953 ........ 12,283.15
The issues to be decided are: (1) Whether dividends which petitioner paid on its preferred stock during the years in issue were, in fact, interest payments and...
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