T.C. Memo. 1997-421
UNITED STATES TAX COURT
MAX BURTON ENTERPRISES, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 26467-95. Filed September 22, 1997.
James A. Jensen, Charles J. Ingber, and Joel P. Leonard,
for petitioner.
Robert S. Scarbrough, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Chief Judge: Respondent determined a deficiency of
$214,220 in petitioner’s Federal income tax for the tax year
ended June 30, 1990. The issue for decision is whether
deductions claimed by petitioner for salary and bonuses paid to
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