Memorandum Findings of Fact and Opinion
The Commissioner determined deficiencies in income tax and additions to the tax under Section 293 (b) for fraud as follows:
Fraud Year Deficiency Penalty 1944 ................. $15,646.28 $7,823.14 1945 ................. 16,531.36 8,265.68
The issues for decision are whether the petitioner received income in each year in...
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