Memorandum Findings of Fact and Opinion
OPPER, Judge:
Deficiencies in income tax and penalties were determined by respondent for the years and in the amounts as follows:
50% Fraud Year Deficiencies Penalty 1943 ............ $1,972.74 $986.37 1944 ............ 1,322.40 661.11 1945 ............ 2,772.75 ......
all of which were placed in issue...
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