Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent has determined deficiencies in the income taxes of petitioner for its fiscal years ending June 30, 1969 and June 30, 1970 in the amounts of $11,833.99 and $24,227.72, respectively.
Due to concessions, the sole issue remaining is whether payments to one of petitioner's officers constituted reasonable compensation for services actually rendered within the meaning of section 162(a)(1).
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