Memorandum Findings of Fact and Opinion
OPPER, Judge:
By this proceeding petitioner challenges respondent's determination of deficiencies in income tax and assessment of penalties for negligence as follows:
Year Deficiency 5% Penalty 1944................ $1,581.58 $79.08 1945................ 1,826.86 91.34
The above deficiencies resulted from respondent's action in adding to petitioner...
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