Memorandum Findings of Fact and Opinion
The Commissioner determined deficiencies in the income taxes of National Creations, Inc., of $1,221.90 for 1945, $3,890.86 for 1946 and $972.44 for 1947 and he also determined that Louis E. Pakula and Jerry Rappaport are liable for those deficiencies as transferees of the assets of the taxpayer. There are two issues for decision (1) whether deductions for officers' salaries taken by the taxpayer for 1946 and 1947 are prohibited...
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