Globe Mortgage Co. v. Commissioner

OPINION.

LeMcre, Judge:

Section 719 of the Internal Eevenue Code provides with respect to borrowed invested capital for excess profits tax credit purposes as follows:

SEO. 719. BORROWED INVESTED CAPITAL.(a) Bokrowed Capita!. — The borrowed capital for any day of any taxable year shall be determined as of the beginning of such day and shall be the sum of the following:(1) The amount of the outstanding indebtedness (not including interest) of the taxpayer which is evidenced by a bond, note, bill of exchange, debenture, certificate of indebtedness, mortgage, or deed of trust, * * *

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