Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined a deficiency of $2,186.96 in petitioner's income tax for the taxable year ending July 31, 1960. The sole issue for our determination after a concession by petitioner is whether $7,191.87 of payments totaling $17,500 to the estate of a deceased shareholder-officer-employee, made in the taxable year ending July 31, 1962, represents deductible compensation...
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