Memorandum Findings of Fact and Opinion
PIERCE, Judge:
The respondent determined a deficiency of $3,000 in the income tax of the petitioner corporation for its taxable calendar year 1961.
The sole issue for decision is whether said corporation is entitled to deduct as ordinary and necessary business expenses for its taxable year 1961, the respective sums of $6,000, $2,000 and $2,000 which it paid in said year to three individuals who at that time...
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