Memorandum Findings of Fact and Opinion
DISNEY, Judge:
This proceeding involves a deficiency of $58,906.22 in income tax for 1944, a 50 per cent penalty thereon of $29,453.11, and interest in the amount of $2,168.23, all of which was the subject of a jeopardy assessment made on October 26, 1945, prior to the mailing of the deficiency notice herein. In his computation of the deficiency the respondent determined that petitioner realized in 1944 taxable income...
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