Memorandum Findings of Fact and Opinion
DISNEY, Judge:
These proceedings, consolidated for hearing and disposition, involve deficiencies in income tax liabilities and the 5 per cent negligence penalty for the years 1944 and 1945, as follows:
Petitioner Docket Deficiency Penalty No. Year John Sito......... 19203 1944 $232.71 $11.64 1945 40.94 ...
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