Memorandum Opinion
TURNER, Judge:
The respondent has determined a deficiency in income tax of $42,521.64 and an addition to tax for fraud of $21,260.84 against John W. Harrison for 1946; and a deficiency in income tax of $26,318.78 and an addition to tax for fraud of $13,159.39 against Clifford F. Harrison for the same year. The question presented for determination in each case was whether or not over-ceiling payments made by Harrison Lumber and Hardware...
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