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1. Prieto conveyed property to her children in 1945 and was later assessed P117K in gift taxes, interest, and penalties in 1954 for the conveyance. 2. Prieto claimed a P55K deduction for interest paid due to late payment of the gift taxes. The CIR disallowed the deduction. 3. The Supreme Court ruled that interest paid for late payment of taxes is deductible under Section 30(b) of the Tax Code as it qualifies as an "indebtedness". Therefore, Prieto

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FSCB

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EN