This case involves deficiencies in excess profits tax liability for calendar years as follows: 1942, $2,831.39; 1943, $3,504.33. The question presented is whether the petitioner's indebtedness to its parent corporation constitutes borrowed capital, within the meaning of section 719 (a) (1), Internal Revenue Code. The parties filed a stipulation of a portion of the facts, which we adopt by reference and find the facts therein set forth. So far as considered material they will...
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