Memorandum Findings of Fact and Opinion
DISNEY, Judge:
This proceeding involves deficiencies in income and excess profits tax liabilities for the year 1941 in the amounts of $1,438.93 and $5,223.85, respectively. Petitioner contends that in making the determination of deficiency, the Commissioner erroneously disallowed $5,500 of the total of $10,000 paid to its three officers and directors for the period of May 17, 1941, to December 31, 1941.
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