Memorandum Opinion
HARLAN, Judge:
This proceeding involves asserted deficiencies in income tax for the calendar years 1940 and 1941 as to R. Godson and for the calendar year 1941 as to E. M. Godson and a delinquency penalty of 25 percent against E. M. Godson for failure to file a return for the calendar year 1941, as follows:
25% Delinquency Taxpayer...
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