OPINION
FEATHERSTON, Judge:
Respondent determined a deficiency of $35,191 in petitioners' Federal income tax for 1972. The issue to be decided is whether petitioners John G. Pahl and Beverley B. Pahl are entitled to a deduction in 1972 for the repayment of that portion of the compensation which petitioner John G. Pahl received in 1969 and 1970 from a corporation he controlled and for which the corporation was not allowed deductions in those years...
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