Memorandum Findings of Fact and Opinion
HALL, Judge:
Respondent determined deficiencies in petitioners' income tax as follows:
Petitioner Year Ended Deficiency Robert & Gertrude Young .......... Dec. 31, 1974 $ 2,828 R. & G. Young Vineyards ...... Nov. 30, 1973 67,716 Nov. 30, 1974 37,532
The sole issue is whether the salary and bonus paid by R. & G. Young Vineyards...
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