Memorandum Findings of Fact and Opinion
OPPER, Judge:
These proceedings involve a deficiency of $12,068.52 in income tax for the calendar year 1949 determined against Faye De Blanc Crasto and Titus Lloyd Crasto, now deceased. The issue for decision is the deductibility of any amount claimed by Titus Lloyd Crasto as compensation paid to employees of his sole proprietorship in the form of stock in the corporate successor to that proprietorship.
Findings...
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