McLAUGHLIN, Circuit Judge:
RAPCO, Inc. ("Rapco") appeals from a judgment of the United States Tax Court (Mary Ann Cohen, Judge). The Tax Court determined that certain compensation paid by Rapco to its president and thereafter deducted by Rapco on its corporate income tax returns was unreasonable. It ordered Rapco to pay income tax on the unreasonable amount. See RAPCO, Inc. v. Commissioner,
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