Memorandum Findings of Fact and Opinion
This proceeding involves determinations of deficiencies in petitioners' income tax for 1944, 1945, and 1946. Fraud penalties are in issue for each of these years. The deficiencies and fraud penalties are as follows:
50% Fraud Year Deficiency Penalty 1944 ............. $ 249.87 $ 124.94 1945 ............. 1,463.63 731.82 1946 ............
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