Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioner's income taxes for its taxable years ended December 31, 1966 and December 31, 1967 in the amounts of $12,767.49 and $10,914.07, respectively. The issue for decision is whether payments made to petitioner's four officer-shareholders in 1966 and 1967 in excess of $16,000 and $16,032.90, respectively, were reasonable compensation for personal services actually...
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