Memorandum Findings of Fact and Opinion
JOHNSON, Judge:
The Commissioner determined a deficiency of $19,482.10 in petitioner's income tax for 1945 and added 5 per cent for their negligence to report all income received. Petitioners admit receipt of unreported poker winnings and some interest, but in an amount substantially less than that determined. They contest imposition of the penalty.
Findings of Fact
Petitioners, husband and wife,...
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