United States Tax Court.
Memorandum Findings of Fact and Opinion
HARLAN, Judge:
The respondent determined deficiencies in income tax and penalties against the petitioner for the calendar years 1937 and 1938 as follows:
Year Deficiency 50% Penalty 1937 ............ $95,789.61 $47,894.81 1938 ............ 94,070.54 47,035.27
Petitioner asserts that he overpaid his tax for the year 1937 in the amount of $1,228.75, and for the year...
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