FINDINGS OF FACT AND CONCLUSIONS OF LAW
STECKLER, District Judge.
This matter is before the Court on plaintiff Shaffstall Corporation's suit for a refund of income tax assessed by the Commissioner of the Internal Revenue Service. Based on an audit of plaintiff's tax return for fiscal year 1979, the Commissioner disallowed $89,951.00 of the plaintiff's deduction for compensation paid to Everett L. Shaffstall (Shaffstall). The Commissioner determined that...
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