MEMORANDUM FINDINGS OF FACT AND OPINION
KORNER, Judge:
Respondent determined the following deficiencies in petitioner's Federal income taxes:
FYE Aug. 31 Deficiency 1990 ......................... $173,346 1991 ......................... 226,072 1992 ......................... 326,591
The issue for decision is whether the compensation paid to petitioner's majority shareholder in its...
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