Memorandum Opinion
JOHNSON, Judge:
In these consolidated proceedings respondent determined income tax deficiencies for the calendar year 1945 as follows:
Docket 5% Negligence No. Petitioner Amount Penalty 22648 Bruce E. and Katherine Gentry ............. $ 3,861.02 ..... 22649 I. A. Craig .......... 19,928.15 $996.41
The parties have...
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