Memorandum Findings of Fact and Opinion
LEECH, Judge:
Respondent has determined a deficiency of $2,335.44 in income tax of petitioner for the calendar year 1940. Petitioner contests the deficiency and claims an overpayment of $5,544.67 upon the ground that it is entitled to a net operating loss carry-over from the year 1939. The issues are (1) whether certain amounts paid by petitioner in 1939 and 1940 as salaries to its first and second vice-presidents...
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