Memorandum Findings of Fact and Opinion
These proceedings were consolidated for hearing and disposition. In the 90-day letters mailed about nine months after the petitioners filed their returns and several weeks after the making of a jeopardy assessment, the respondent determined an income tax deficiency of $43,713.43 and a 50 per cent fraud penalty of $21,856.72 against each petitioner for the calendar year 1944. These deficiencies were determined on the basis...
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