Memorandum Findings of Fact and Opinion
OPPER, Judge:
This proceeding arises out of respondent's determination of a deficiency in income tax of $571 for 1946, of which about $282 is in controversy, together with a 5 per cent penalty for negligence of $28.55. Respondent's determination was based upon computations of petitioner's "net worth" and an estimate of his expenditures. Certain adjustments are not contested, additional tax having been paid. The primary...
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