Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
Respondent determined a deficiency in income tax of $4,427.22 and a fraud penalty of $2,213.61, for the calendar year 1945.
The issues to be decided are whether petitioner received unreported income in 1945 in the amount of $10,122.01 as determined by respondent and whether respondent erred in the determination of the 50 per cent fraud penalty pursuant to section 293 of the Internal Revenue...
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