EVANS, Circuit Judge.
Petitioner is a Wisconsin corporation against whom respondent assessed a $40,940.28 deficiency tax for 1936. On an appeal to the Board of Tax Appeals, the assessment was sustained. 44 B.T.A. 460.
The controversy is over an item of $112,564.97, which was paid by petitioner in connection with petitioner's purchase of the late Mr. Nieman's stock in the Journal Company. The parties differ as to whether this payment was an interest payment...
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