Memorandum Findings of Fact and Opinion
The respondent determined deficiencies in income tax of petitioner for the years 1951 and 1952 in the respective amounts of $266,685.74 and $6,935.01.
The sole issue in controversy is whether advances made by petitioner to International Meters, Inc. aggregating $506,887.06 represent contributions to the capital of that corporation or an indebtedness. If they represent an indebtedness, the respondent concedes that petitioner...
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