OPINION.
VAN FOSSAN, Judge:
The respondent determined a deficiency in petitioner's income tax for the taxable year ended June 30, 1951, in the amount of $2,221, with a penalty of $383.35 under section 294 (d) (2), Internal Revenue Code of 1939. The penalty and certain minor adjustments are not contested. The parties stipulate that the issue between them "is whether petitioner could properly deduct the sum of $8,707.03, representing interest accrued...
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