Memorandum Findings of Fact and Opinion
WRIGHT, Judge:
Respondent determined deficiencies in petitioner's Federal income tax for its fiscal year ending April 30, 1986, in the amount of $13,148.28, and for its fiscal year ending April 30, 1987, in the amount of $12,506.40.
The issue for decision is whether payments made to Mary Schusler by petitioner, and payroll taxes paid on account of Mary Schusler, are
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