The Commissioner determined income tax deficiencies against the petitioners of $117,054.16 for 1952 and $232,678.86 for 1953. The principal issues for decision are whether the Commissioner erred in disallowing deductions for each year for interest paid on indebtedness and whether interest income was received when non-interest-bearing notes were sold. Alternative errors were alleged.
FINDINGS OF FACT.
The petitioners, husband and wife, filed their income...
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