Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $195,281 in petitioner's Federal income tax for the fiscal year ended June 30, 1990. The sole issue remaining for decision is whether officer's compensation of $818,533 paid to Donald Palmer (Palmer) is unreasonable and thus not deductible by petitioner.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year...
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