JOHN R. BROWN, Circuit Judge.
This case presents primarily the question of the accrual of interest as a deduction to the payor corporation on an obligation owing to its controlling stockholder-officer-director. The Commissioner in a deficiency assessment treated the obligation as a debt for which interest would be payable and deductible. But he concluded that it was accruable during each of the four years and not, as Taxpayer treated it, in the final (fourth) year...
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