Memorandum Findings of Fact and Opinion
The respondent has determined deficiencies in income tax for the calendar year 1949 in the amount of $1,063,555.43 and in income and excess profits taxes for the calendar year 1950 in the amount of $1,275,510.88.
The questions presented are: (1) whether distributions from annual profits to stockholder-employees in proportion to such stockholdings constitute, in whole or in part, additional compensation payments for...
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