Memorandum Findings of Fact and Opinion
EKMAN, Judge:
Respondent determined a deficiency in petitioner's Federal income tax for the taxable year ended July 31, 1974 in the amount of $30,024.22.
Petitioner having made certain concessions, the sole issue for decision is whether petitioner is entitled to deduct, pursuant to section 162(a)(1), amounts paid as salary to employees who were also shareholders of petitioner.
Findings of Fact
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