Universal Castings Corporation, an Illinois Corporation v. Commissioner of Internal Revenue

SCHNACKENBERG, Circuit Judge.

By its petition, Universal Castings Corporation, an Illinois corporation, asks us to review a decision of the Tax Court of the United States that there were deficiencies in its income tax payments for the taxable years 1953, 1954 and 1955.

There appears little conflict in the evidentiary facts, some of which were stipulated. The contested issue is whether the Tax Court erred in finding as not deductible for federal income tax purposes the amounts paid as interest by petitioner on its “Income Notes” during those years.

Petitioner contends that the Tax Court’s…