Supplemental Memorandum Opinion
HARRON, Judge:
The respondent determined a deficiency in income tax for the fiscal year ended March 31, 1964, in the amount of $3,148.10. The issue is whether the petitioner's deferred profit-sharing plan, which covers only its three salaried employees, is a qualified plan under section 401(a), 1954 Code, so that petitioner is entitled to a deduction of $11,238.75 which it contributed to its plan in the taxable year. Respondent...
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