Memorandum Findings of Fact and Opinion
TYSON, Judge:
The respondent determined deficiencies in petitioner's income taxes in the amounts of $4,325.68 and $1,779.86 for the calendar years 1940 and 1941, respectively, and, also determined a five per cent penalty in the amount of $88.99 for the year 1941, because petitioner's return for that year was not filed within the time prescribed by law.
The sole...
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