Memorandum Findings of Fact and Opinion
Respondent determined deficiencies in petitioner's Federal income taxes for the years 1953, 1954, 1956, and 1957 in the respective amounts of $3,435.42, $4,225.09, $17,868.23, and $2,195.89. That part of the deficiencies here in issue arises by reason of respondent's determination that certain amounts paid by petitioner to The Philadelphia National Bank were "not deductible as interest paid within the meaning of" section 23...
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