Memorandum Findings of Fact and Opinion
The Commissioner determined deficiencies in petitioner's income tax for fiscal years ended October 31, 1944, 1945 and 1946 in the amounts of $585.92, $5,371.45 and $1,202.79, respectively. Except for disallowance of a deduction for New York franchise taxes in the amount of $343.17 in the fiscal year 1945, these deficiencies resulted from partial disallowance of deductions claimed for compensation of petitioner's officers....
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