Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
The Commissioner has determined a deficiency in petitioner's income tax for the fiscal year ended September 30, 1960, in the amount of $1,440. The sole question for our decision is the propriety of his determination that a deduction of $7,200 (claimed as compensation paid to petitioner's president and sole stockholder), during the year in issue, was excessive, and that $2,400 was a reasonable allowance...
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