Memorandum Findings of Fact and Opinion
WHALEN, Judge:
Respondent determined a deficiency of $533,748.86 in petitioner's Federal income tax for 1984, and a deficiency of $544,056.60 in petitioner's Federal income tax for 1985. The issue for decision is whether the compensation paid to petitioner's president and sole shareholder, Mr. Larry Van Tuyl, is deductible under section 162(a)(1). All section references...
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