Memorandum Findings of Fact and Opinion
This proceeding involves deficiencies in income tax determined against petitioner for the fiscal years ended June 30, 1947, and June 30, 1948, in the amounts of $5,794.98 and $6,246.48, respectively.
The sole issue to be decided is whether petitioner is entitled to deduct, under section 23(b) of the 1939 Code, amounts which it accrued as interest on advances made to it by its stockholders.
If this issue is...
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