SNARE v. COMMISSIONER

Memorandum Findings of Fact and Opinion

OPPER, Judge:

Petitioner challenges respondent's determination of deficiencies in income tax and of delinquency penalties of 25 percent for failure to file returns within the time prescribed by law, for the calendar years 1940, 1941, and 1943, as follows:

  Year                  Tax Deficiency  Penalty

  1940.................   $   41.74     $ 10.43
  1941.................      264.00       66.00
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