Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined a deficiency in petitioner's income tax for its fiscal year ended May 31, 1961, in the amount of $39,324.78. The only issue is whether there should be included in petitioner's taxable income for its fiscal year ended May 31, 1961, the sum of $97,839.99 paid to three of petitioner's stockholders, each of whom owned 25 percent of petitioner's stock, by a partnership, West Realty...
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