United States Tax Court.
Memorandum Findings of Fact and Opinion
The Commissioner has determined deficiencies in petitioners' income tax and penalties, as follows:
Year Deficiency 50% Penalty 1945............... $3,287.20 $1,643.60 1946............... 2,900.54 1,450.27
The deficiency for 1945 was determined by the Commissioner making the following adjustments to the net income disclosed by petitioner's return:
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