The Commissioner determined a deficiency in income tax for the year 1952 in the amount of $8,439.80. The question is whether there was a payment in 1952 of interest in the amount of $12,953.90 on deficiencies in income tax for prior years within the provisions of section 23 (b), 1939 Code, for which petitioners are entitled to a deduction in 1952.
The Commissioner determined that for the year 1951 an addition to tax is due under section 294 (d) (2) in the amount of...
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