FRANK, Circuit Judge.
We think that the Tax Court correctly held that the assumption by taxpayer on June 17, 1938, of the liabilities of Gladstone in exchange for Gladstone's assets was a capital transaction in the nature of consideration for the receipt of the assets of Gladstone, and that interest paid in that year, which had accrued before such purchase, was not "interest" within the meaning of § 23(b). Nor do we think that the payment of $32,569.33 representing...
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