SIMPSON, Judge:
The respondent determined deficiencies in the petitioner's Federal income tax of $803,786.42 for the taxable year ended June 30, 1962, and $572,199 for the taxable year ended June 30, 1963. In his amended answer, the respondent claimed an additional deficiency of $107,389.40 for 1963. Most of the issues in the case have been settled; the one issue remaining for decision is whether a corporation which issues convertible debentures at par may...
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