Frank Petar Contracting, Inc. - Page 15

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               For the aforesaid reasons, the evidence does not persuade us           
          that petitioner paid the accrued bonus by means of a promissory             
          note before the close of the taxable year in issue.  Petitioner             
          has not satisfied its burden of proof.  We therefore sustain                
          respondent’s disallowance of the deduction.                                 
               To reflect the foregoing,                                              

          Decision will be entered                                                    
          for respondent.                                                             































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Last modified: May 25, 2011