Memorandum Findings of Fact and Opinion
GERBER, Judge:
Respondent determined deficiencies in petitioners' joint Federal income taxes for calendar years 1978 and 1979 in the amounts of $31,104.54 and $16,749.25, respectively. The issue presented for consideration is whether a shareholder-officer of a corporation may deduct amounts paid with respect to the 100-percent assessment under section 6672
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