Memorandum Findings of Fact and Opinion
HARRON, Judge:
Respondent determined a deficiency in income tax for the year 1941 in the amount of $263.59. The deficiency results from disallowance of a deduction of $1,200 which was claimed to be an expense on account of the alleged salary of an officer. Petitioner concedes that the deduction is not allowable.
Petitioner makes claim, for the first time, in its petition for deduction in the year 1941