Memorandum Findings of Fact and Opinion
FISHER, Judge:
Respondent determined a deficiency in the income tax of petitioner for the taxable year 1957 in the amount of $16,395.42.
The issues presented for our consideration are: (1) Whether $2,600 paid by petitioner to George P. Thomas in the taxable year 1957 constituted payment of interest on indebtedness of petitioner under section 163, Code of 1954;
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