Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined deficiencies in petitioner's income taxes of $2,841.20 and $1,875.22 for the taxable years ended July 31, 1949 and July 31, 1950, respectively. Certain adjustments are not contested. The remaining questions are (1) Whether alleged salaries paid to two of petitioner's officers in each year were properly disallowed in their entirety as being distributions of earnings to stockholders...
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