Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioner's Federal income tax for the calendar years 1969 and 1970 in the amounts of $16,684.79 and $21,473.51, respectively.
The issue for the year 1969 is whether amounts deducted for compensation paid by petitioner to its two officer-employees were reasonable within the meaning of section 162, I.R.C. 1954.
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