ACME CONSTRUCTION CO., INC. v. COMMISSIONER

Memorandum Findings of Fact and Opinion

COLVIN, Judge:

Respondent determined a $122,188 deficiency in petitioner's Federal income tax for the taxable year ending April 30, 1990 (fiscal year 1990).

The sole issue for decision is whether petitioner may deduct as reasonable compensation amounts it paid to David Horth in fiscal year 1990. The following chart shows the contentions of the parties and the amount allowed by this opinion:

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