Memorandum Findings of Fact and Opinion
JOHNSON, Judge:
In these consolidated proceedings respondent has determined deficiencies in income tax, fraud penalties and delinquency penalties against the petitioner in Docket No. 23814, Puritan Church-The Church of America, as follows:
Year Deficiency 25% Penalty 50% Penalty Fiscal period Oct. 14, 1945, to Dec. 31 — 1945 ............
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