Respondent has determined deficiencies in the income tax of petitioners for the years 1954 and 1955 in the amounts of $70,994.26 and $139,795.28, respectively, and an addition to tax for 1954 under section 294(d)(2) of the 1939 Code in the amount of $5,260.87. In the determination of the deficiency for 1954, the Commissioner added to the taxable income reported on the joint return filed by petitioners for 1954 "(a) Interest expense $92,407.50." This adjustment was explained...
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