DAWSON, District Judge.
This is a suit for a refund of income taxes for the year 1923. The whole case hinges on whether or not the so-called debenture stock issued and sold by the plaintiff was, in fact, capital stock, or represented borrowed money. These securities were sold at 50 per cent. discount. The plaintiff contends that the so-called 6 per cent. dividends on this stock should be treated as interest paid on borrowed money and allowed as a deduction, under...
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