Memorandum Findings of Fact and Opinion
This proceeding involves a deficiency in income tax of petitioner for the fiscal year ended July 31, 1951, in the amount of $36,193.25.
The issue presented is whether the sum of $91,962.62 paid or credited by petitioner to its president, Ellis A. Lando, in the fiscal year ended July 31, 1951, as compensation is reasonable within the meaning of section 23(a)(1)(A), Internal Revenue Code of 1939.
Findings of...
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