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allow double deductions for the same amount ‘absent a clear
declaration of intent by Congress,’ * * * and we not think
section 162(a) reflects any such intent.” Brenner v.
Commissioner, 62 T.C. 878, 885 (1975) (quoting United States v.
Skelly Oil Co., 394 U.S. 678, 684 (1969)).
In view of the foregoing, we sustain respondent’s
determination and hold that petitioner is not entitled to any
deduction for repayment of principal on the loan from Providian
Bank.
C. Conclusion
Reviewed and adopted as the report of the Small Tax Case
Division.
To give effect to our disposition of the disputed issues, as
well as the parties’ concessions, see supra note 2,
Decision will be entered
under Rule 155.
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