Memorandum Findings of Fact and Opinion
TYSON, Judge:
The Commissioner determined a deficiency in income tax of $103,080 for the year 1929, and, finding that the deficiency was due to fraud with intent to evade tax, he added a penalty of $53,274.62. The deficiency arises from the following adjustments by the Commissioner: (1) The inclusion in income of $388,500, that amount being the fair market value of 111,000 shares of stock of the Bagdad Copper Corporation...
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