Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The Commissioner determined deficiencies in the petitioner's Federal income taxes in the amounts of $27,942.00 for 1971 and $37,448.00 for 1972. The issue for decision is whether the amounts paid to the petitioner's two officer-shareholders for the years in issue constituted reasonable compensation for services rendered within the meaning of section 162(a)(1) of the Internal Revenue Code of 1954.
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