Memorandum Findings of Fact and Opinion
BRUCE, Judge:
These consolidated cases involve deficiencies determined by respondent for the year 1964 in the income taxes of John C. Hagen and wife, Mary Hagen, in the amount of $5,291.06, and of Fred J. Hagen and wife, Floy J. Hagen, in the amount of $5,142.75. The only issue presented is whether a payment of $475,000 in full discharge of an indebtedness in the principal amount of $455,000 and accrued interest in...
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