Memorandum Findings of Fact and Opinion
WILBUR, Judge:
Respondent has determined a deficiency in petitioners' Federal income tax for the taxable year 1968 in the amount of $261,388. The issues presented for decision are (1) whether a $500,000 payment by petitioners should be regarded as prepaid interest or a down payment and (2) if the payment represents interest, whether petitioners are entitled to deduct the entire sum in 1968 or whether the deduction...
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