Memorandum Findings of Fact and Opinion
TRAIN, Judge:
The respondent determined deficiencies in income tax of the petitioner for the taxable years ended March 31, 1956, and March 31, 1957, in the amounts of $2,395.60 and $689.08, respectively. Petitioner claims an overpayment of tax for the year ended March 31, 1957.
The only issue for decision is whether respondent erred in disallowing the deduction of personal service compensation payments to the...
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