Memorandum Findings of Fact and Opinion
In this proceeding the respondent has determined a deficiency in petitioner's excess-profits tax for the year 1941 in the amount of $3,148.92. This deficiency arises by reason of respondent's determination that petitioner's indebtedness to Mill Factors Corporation did not constitute borrowed capital for the year 1941 within the meaning of section 719 of the Internal Revenue Code.
Findings of Fact
The petitioner...
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