Memorandum Findings of Fact and Opinion
ARUNDELL, Judge:
Respondent determined a deficiency in income tax for the taxable year ended October 31, 1954, in the amount of $6,628.90.
The issues involved are: (1) Whether respondent erred in disallowing $12,000 deducted by petitioner on its return as interest paid on indebtedness; and (2) whether respondent erred in disallowing $456 deducted by petitioner on its return as Pennsylvania loans tax.
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