Memorandum Findings of Fact and Opinion
PIERCE, Judge:
The respondent determined deficiencies in petitioner's income taxes for the calendar years 1953 and 1954 in the respective amounts of $16,996.74 and $16,804.55.
The question presented for decision is whether petitioner is entitled to deduct, as interest under sections 23(b) of the 1939 Code and 163(a) of the 1954 Code, amounts paid with respect to certain alleged "loans" made on the security...
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