Memorandum Findings of Fact and Opinion
SMITH, Judge:
This proceeding is for the redetermination of deficiencies in income tax and penalty for the calendar years as follows:
Year Deficiency 25% Penalty 1936 ................. $ 80.80 ..... 1937 ................. 445.46 ..... 1938 ................. 160.82 $40.20 1939 ................. 92.51 .....
The petitioner has alleged...
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