Memorandum Findings of Fact and Opinion
HILL, Judge:
Respondent determined a deficiency in petitioner's income tax for 1941 in the amount of $2,962.93. Respondent further added a five per cent penalty of $148.15 under section 293 (a) of the Internal Revenue Code. The questions are, (1) whether certain dividends paid in 1941 are taxable to petitioner or to his son, and (2) whether petitioner is subject to a penalty under section 293 (a) for failing to report...
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