Memorandum Findings of Fact and Opinion
QUEALY, Judge:
In Docket No. 3560-70, the respondent determined deficiencies in the income tax of petitioner Royal Arrow Co., Inc. in the respective amounts of $3,360 for the taxable year ended December 31, 1966 and $12,000 for the taxable year ended December 31, 1967. The only question presented for decision is whether certain amounts paid in 1966 and 1967 by said petitioner to Hugh P. and Rosa Emerson pursuant to...
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