SETH, Circuit Judge.
This appeal has been taken from a judgment by the trial court which dismissed part of appellant taxpayer's claim for refund of federal corporate income taxes. The taxpayer claimed a refund for the years 1955 and 1957 based upon loss carry-backs. In computing the losses taxpayer deducted certain payments it had made as interest on promissory notes given to its parent corporation, National Farmers Union. The Commissioner disallowed these deductions...
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