Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioner's income taxes for the calendar years 1973 and 1974 in the amounts of $1,810.09 and $79,793.54, respectively.
The issues for decision are:
(1) Whether the compensation paid by petitioner for the year 1974 to two of its officers, Mr. Fred Peterson and Mr. Robert Peterson, was unreasonable pursuant to section 162, I.R.C. 1954,
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