FINDINGS OF FACT AND OPINION.
The respondent determined deficiencies in excess profits tax for the calendar years 1942, 1943, 1944, and 1945 in the respective amounts of $4,398.39, $8,148.53, $6,724.69, and $10,445.73, and a deficiency in declared value excess-profits tax for 1943 in the amount of $38.54.
The primary issue for decision is whether the petitioner is entitled to include as borrowed capital under section 719 (a) (1) of the Internal Revenue Code...
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