Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes of $18,719 and $15,934 for its taxable years ending December 31, 1972, and December 31, 1974, respectively. The only question presented is whether certain payments by petitioner for gifts made by a sales representative are subject to the $25 per individual recipient gift expense limitation set forth in section 274(b).
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