Memorandum Findings of Fact and Opinion
COLVIN, Judge:
Respondent determined deficiencies in petitioner's Federal income tax for 1986 in the amount of $23,706.
The sole issue for decision is whether petitioner, an accrual basis taxpayer, may deduct for taxable year 1986 bonuses for its two 50-percent owners which were declared in early March 1987 but which have never been paid. As discussed below, we hold that petitioner may not deduct the bonuses...
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