Memorandum Findings of Fact and Opinion
OPPER, Judge:
By this proceeding petitioners challenge respondent's determination of deficiencies in income tax and penalty, as follows:
1943 ............ $2,726.961 1944 ............ 1,525.25
The year 1942 is involved by virtue of the provisions of the Current Tax Payment Act of 1943.
The deficiencies...
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