Memorandum Opinion
ARNOLD, J.:
This proceeding involves a deficiency in income tax in the amount of $1,628.07 for the year 1938. The only question involved is whether the amount of $9,000 paid by petitioner in 1938 to the holders of its 6 percent preference debentures was interest and as such deductible from gross income under section 23 (b) of the Revenue Act of 1938. The return was filed with the collector of internal revenue for the first district of...
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