MEMORANDUM FINDINGS OF FACT AND OPINION
PARR, Judge:
Respondent determined deficiencies in petitioner's Federal income tax of $370,158 for the taxable year ending October 31, 1995, and $317,261 for the taxable year ending October 31, 1996.
The issue for decision is whether petitioner may deduct as officer compensation paid to Dennis Wagner (Dennis) and Curtis Wagner (Curtis) for taxable years ending October 31, 1995 and 1996, the amounts shown below...
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