Memorandum Findings of Fact and Opinion
HARLAN, Judge:
The respondent determined deficiencies in gift tax against petitioner and asserted penalties for failure to file gift tax returns, as follows:
Year Gift Tax Penalty 1938.................... $ 585.57 $ 146.39 1939.................... 1,066.51 266.63 1941.................... 459.80 114.95 1942.................... 1,141.60...
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