Memorandum Findings of Fact and Opinion
OPPER, Judge:
Petitioner contests respondent's determination of deficiencies in income tax for 1943 to 1946, inclusive, in the amounts of $1,309.11, $21,037.98, $442.13, and $793.02, respectively, together with a 25 per cent penalty of $327.28 for failure to file a return in 1943, and 50 per cent fraud penalties for 1943 to 1946, inclusive, in the amounts of $654.56, $10,518.99, $221.07, and $396.51, respectively....
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