Memorandum Findings of Fact and Opinion
LEECH, Judge:
This proceeding involves deficiencies in income taxes of $3,167.87 and excess-profits taxes of $1,400.17 determined against the petitioner for the year 1938.
The issue is whether the Commissioner correctly determined that the sum of $25,508.65, representing accrued but unpaid portion of salaries of officer-stockholders for 1936 and 1937 transferred from so-called officers' "Loan Accounts" to surplus...
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