OPINION.
TYSON, Judge:
This proceeding involves deficiencies in the amounts of $12,948.41 in income tax and $3,028.16 in declared value excess profits tax determined by respondent against petitioner for the fiscal year ended October 31, 1943.
Questions presented are whether the respondent erred in denying petitioner:
(1) A deduction of $10,589.23 as interest alleged to have accrued during the taxable year on an instrument designated...
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