Memorandum Findings of Fact and Opinion
These proceedings, consolidated for hearing and opinion, involve income tax deficiencies and penalties for 1946 and 1947, as follows:
Negligence Year Deficiency Penalty Docket No. 23246.. 1946 $10,088.80 $504.44 1947 24,725.75 ....... Docket No. 23247 1946 10,136.30 506.82 ...
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