Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined deficiencies in petitioner's Federal income tax as follows:
Taxable Year Ended Deficiency April 30, 1972 .................. $28,856.87 April 30, 1973 .................. 33,108.66
Concessions having been made, the sole issue for decision is whether the amounts paid by petitioner to its two officer-shareholders...
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