MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
Petitioner petitioned the Court to redetermine an income tax deficiency of $546,634 for 1990. The deficiency stems from respondent's determination that petitioner may not deduct $1,750,000 paid to its shareholder/employee in 1993 reportedly as compensation. Petitioner reported a net operating loss (NOL) for 1993 that it carried back to 1990.
We must decide the following issues:
1. Whether...
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