OPINION.
STERNHAGEN, Judge:
Income tax deficiencies of $3,513.07 for 1940 and $5,499.73 for 1941 were determined by the Commissioner. The taxpayer assails the disallowance of deductions taken for interest paid upon notes held by a divorced wife. The facts are all stipulated. The return was filed in Jacksonville, Florida.
On May 18, 1931, the taxpayer and his wife, who had been married on January 15...
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