MEMORANDUM FINDINGS OF FACT AND OPINION
SCOTT, Judge:
Respondent determined a deficiency in petitioner's Federal income tax for its fiscal year ending June 30, 1990, in the amount of $100,784, and a penalty under section 6662(b)(2) in the amount of $24,667. Some of the issues raised by the pleadings have been disposed of by agreement of the parties, leaving for decision: (1) Whether petitioner is entitled to a deduction as a trade or business expense of...
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