Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
This proceeding involves deficiencies in income tax for the taxable years ended December 31, 1944 and 1945, in the respective amounts of $1,084.45 and $1,384.66.
The issue presented is whether or not respondent erred in disallowing as deductions in 1944 and 1945 amounts of $4,188 and $4,000, respectively, of total annual compensation of $6,200 in each year paid to an officer of petitioner corporation...
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