The Commissioner has determined a deficiency of $7,491.10 in petitioner's income tax and of $1,417.13 in its declared value excess profits tax for the year 1939.
The sole issue before us for determination is whether certain payments made by petitioner during the taxable year 1939 to the holders of its "series A debenture bonds" constitute dividends on stock which were not deductible from gross income, as determined by respondent, or whether they constitute payments...
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