MEMORANDUM OF FACT AND OPINION
GOEKE, Judge:
On January 6, 2003, respondent issued a notice of deficiency determining Federal income tax deficiencies for petitioner's tax years ended June 30, 1998, 1999, and 2000, of $82,686, $83,016, and $103,855, respectively. Among other things, respondent partially disallowed petitioner's deductions for compensation paid to its shareholder-employees of $204,577 in 1998...
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