Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined a deficiency in income tax for 1946 of $17,185.99 resulting from the disallowance as a deduction of $45,226.29 out of total compensation of $70,226.29 paid to petitioner's president. Some of the facts were stipulated.
Findings of Fact
The stipulated facts are hereby found.
Petitioner is a California corporation organized in November 1936 as the Jimmy Dixon...
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