MEMORANDUM FINDINGS OF FACT AND OPINION
PARR, Judge:
Respondent determined a deficiency in petitioner's 1990 Federal income tax of $1,376,520, and a penalty under section 6662
The issues for decision are: (1) Whether an amount paid by petitioner to William T. Rogers (Rogers) as compensation during taxable year 1990 is reasonable within the meaning of section 162(a)(1). We find the amount paid was not reasonable...
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