Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined deficiencies in petitioner's corporate income taxes for the taxable years ending March 31, 1969, and March 31, 1970, of $17,001.59 and $20,616.54, respectively. Some of the adjustments giving rise to these deficiencies have been conceded by petitioner. The sole issue remaining to be decided is whether under section 162(a)(1), I.R.C. 1954,
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