Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined a deficiency in Frank and Lillian Cohen's income tax for the year 1960 in the amount of $50,471.
Concession having been made, the only issues remaining for us to decide are: (1) whether prepaid interest on a loan, the proceeds of which were used to purchase U. S. Treasury notes, is deductible; (2)
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