MEMORANDUM AND ORDER
FULLAM, District Judge.
Plaintiff Theodore J. Evans is the president and principal stockholder of Colonial Tire Service of West Chester, Inc., a closely held corporation. At issue in these consolidated tax-refund proceedings is whether certain expenditures by the corporation in tax years 1977 and 1978 were reasonable and necessary business expenses of the corporation, or should be treated as constructive dividends to Mr. Evans.
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