Memorandum Findings of Fact and Opinion
The respondent determined a deficiency of $2,531.47 in the petitioner's income tax for its taxable year ending October 31, 1937.
The sole issue is the respondent's disallowance, as an ordinary and necessary business expense, of $31,473.40, representing the discounted value of the petitioner's obligation to pay $36,000 to two former stockholders under a so-called employment contract.
Findings of Fact
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