Memorandum Findings of Fact and Opinion
RAUM, Judge:
The Commissioner determined a deficiency in income tax against petitioner for its fiscal year ending October 31, 1963 in the amount of $3,983.18 plus an addition for fraud in the amount of $1,991.59 pursuant to section 6653(b), I. R. C. 1954. Three adjustments made by the Commissioner are presently in controversy: (1) the disallowance of a deduction for salaries and wages to the extent of $9,831; (2) the...
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