Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent has determined deficiencies in the Federal income tax of petitioner Key Buick Company for the calendar years 1967, 1968 and 1969 in the amounts of $9,600, $101,737.30 and $54,990.88, respectively.
The issues for decision are (1) Whether petitioner is entitled to deduct as a salary expense under section 162, I.R.C. 1954,
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