Memorandum Findings of Fact and Opinion
HARRON, Judge:
Respondent determined deficiencies in income tax for the years 1955 and 1956 in the amounts of $55,358.90 and $90,359.55, respectively. The question is whether the petitioner, Sidney B. Lifschultz, is entitled to a deduction in each year under section 163(a), 1954 Code, as interest paid on indebtedness, of $36,241.25 in 1955, and $78,866.08 in 1956.
The parties have entered into stipulations...
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