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COZART PACKING COMPANY, INC. v. COMMISSIONER

Docket No. 3936-70.

31 T.C.M. 867 (1972)

T.C. Memo. 1972-175

Cozart Packing Company, Inc. v. Commissioner.

United States Tax Court.

Filed August 16, 1972.

Attorney(s) appearing for the Case

Stanley Worth, Brawner Bldg., 888 Seventeenth St., Washington, D.C., for the petitioner. Frank D. Armstrong, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

IRWIN, Judge:

Respondent determined the following deficiencies in the income tax of petitioner:

  Year                 Deficiency

  1966 ...............  $2,895.26
  1967 ...............   1,452.00
  1968 ...............   3,484.80

The deficiencies all stem from respondent's disallowance of deduction in each year of $6,600 of $9,000 paid as salary by petitioner to Robert T. Cozart, Jr....

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