Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined deficiencies in petitioner's income tax for the taxable years 1963 and 1964 in the respective amounts of $10,798.96 and $13,470.72. After concessions by both parties, the only issue is whether amounts paid to its president and sole stockholder in these taxable years was reasonable compensation for services rendered.
Findings of Fact
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