The Commissioner determined a deficiency in each petitioner's 1957 income tax in the amount of $4,702.22. At issue is whether the Commissioner erred in disallowing as a deduction, under section 163(a), I.R.C. 1954, an amount paid allegedly as "interest" on funds purportedly borrowed from Corporate Finance Corp. allegedly to purchase securities.
FINDINGS OF FACT
The facts stipulated by the parties and exhibits introduced in evidence are incorporated herein...
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