MARIS, Circuit Judge.
This is a petition to review a decision of the Board of Tax Appeals. First Mortgage Corporation of Philadelphia, the petitioner, claimed deductions in its income tax returns for the years 1936 and 1937 for payments made to its preferred stockholders in those years. It claimed these payments to be interest upon its indebtedness and deductible as such by virtue of section 23(b) of the Revenue Act of 1936, 26 U.S. C.A. Int.Rev.Code, § 23(b...
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