Memorandum Findings of Fact and Opinion
SHIELDS, Judge:
The respondent determined that there are deficiencies in the income tax due from the petitioner for the years 1974 and 1975 in the respective amounts of $961.68 and $42,090.00. The deficiencies resulted from the disallowance by the respondent of deductions claimed by the petitioner, a paving subcontractor, for certain payments made for the benefit of an employee of one of the petitioner's general contractors...
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