Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined deficiencies in income tax and penalties for the fiscal years ended October 31, 1940, and October 31, 1941, in the following amounts, all of which are in issue:
Deficiency Penalty 1940 ................... $ 78.65 $19.66 1941 ................... 60.91 15.23 _______ ______ ...
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