Devine Brothers, Inc. - Page 1

                                 T.C. Memo. 2003-15                                   

                               UNITED STATES TAX COURT                                

                        DEVINE BROTHERS, INC., Petitioner v.                          
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 8135-01.              Filed January 16, 2003.               

               Lowell F. Raeder and David R. White, Jr., for petitioner.              
               Gerald A. Thorpe, for respondent.                                      

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               COHEN, Judge:  Respondent determined a deficiency of $25,086           
          in petitioner’s Federal income tax for the fiscal year ended                
          February 28, 1995.  After concessions, the issue for decision is            
          whether deductions claimed by petitioner for salary and bonuses             
          paid to one of its officers, who was also a shareholder, exceeded           
          reasonable compensation.  Unless otherwise indicated, all section           

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