Memorandum Findings of Fact and Opinion
TYSON, Judge:
This proceeding involves income tax deficiencies and fraud penalties determined by respondent against the petitioner for the calendar years and in the amounts as follows:
Year Deficiency Fraud Penalty 1941... $ 514.09 $ 382.52 1942... 5,823.34 2,911.67
The issues presented by the pleadings are whether respondent erred: (1) In including in petitioner...
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