Memorandum Findings of Fact and Opinion
MULRONEY, Judge:
Respondent determined a deficiency in petitioner's income tax for the fiscal years ended January 31, 1963 and 1964 in the respective amounts of $5,850 and $12,408.06. The only issue is whether the amounts of salary paid to Robert R. Rodgers, petitioner's principal officer, in the fiscal years ended January 31, 1963 and 1964 were reasonable compensation within the meaning of section 162 of the 1954...
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