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UNIVERSAL CASTINGS CORPORATION v. COMMISSIONER

Docket No. 79407.

37 T.C. 107 (1961)

UNIVERSAL CASTINGS CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 31, 1961.

Attorney(s) appearing for the Case

Robert A. Helman, Esq., and Marshall G. Sampsell, Esq., for the petitioner.

Joel Yonover, Esq., for the respondent.

MULRONEY, Judge:

The respondent determined deficiencies in petitioner's income tax of $8,260 in 1953, $6,136 in 1954, and $6,136 in 1955. Petitioner deducted as interest payments to holders of its 5-percent income notes in each of the years in question. Respondent disallowed the deductions. The sole question for decision is the correctness of respondent's disallowance.

FINDINGS OF FACT.

Some of the facts have been stipulated and they are found...

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