Memorandum Opinion
FORRESTER, Judge:
Respondent determined deficiencies in petitioner's income tax for the taxable years 1957 and 1958 of $6,000.34 and $5,275.90, respectively. The only issue is whether certain payments to petitioner were interest, thereby subjecting it to the personal holding company tax imposed by section 541 of the Internal Revenue Code of 1954.
All of the facts have been stipulated and are so found...
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