Memorandum Findings of Fact and Opinion
RAUM, Judge:
The respondent determined a deficiency in the income tax of petitioner for the calendar year 1944 in the amount of $42,831.41.
The sole question is whether the respondent erred in disallowing a deduction of $58,500 claimed by petitioner in 1944 for amortization of the excess of the amount of the cost of certain American Telephone and Telegraph Company 15-year 3 per cent convertible debenture bonds...
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