Docket No. 64648.

18 T.C.M. 443 (1959)

T.C. Memo. 1959-99

Robert M. Diggs and Clara C. Diggs v. Commissioner.

United States Tax Court.

Filed May 19, 1959.

Attorney(s) appearing for the Case

Robert M. Diggs, pro se, Olean, N. Y. Emil Sebetic, Esq., for the respondent.

Memorandum Findings of Fact and Opinion


Respondent determined deficiencies in the petitioners' income tax for the years 1952 and 1953 in the respective amounts of $5,155 and $18,132.60. The issues are:

(1) Whether certain payments made by the petitioners in the years 1952 and 1953 are deductible as interest within the meaning of section 23(b) of the Internal Revenue Code of 1939;1 and

(2) Whether...

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