Memorandum Findings of Fact and Opinion
This proceeding involves the determination by the respondent of a deficiency in income tax for the taxable fiscal year ended July 31, 1941, in the amount of $5,340.17.
The only issue involved is whether certain payments which petitioner made in the taxable year to its debenture holders represented interest paid to them on indebtedness, or whether these debentures represented a proprietary interest in the business and...
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