The respondent determined a "deficiency in penalty" in the amount of $1,114.22 for the year 1947, consequent on the failure of the petitioner to file a declaration of estimated tax for that year. The only question raised by the pleadings is whether petitioner is subject to such addition to his income tax because of such failure to file.
FINDINGS OF FACT.
The petitioner is Rene R. Bouche, a painter and artist who came to the United States from France in 1941...
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