Memorandum Findings of Fact and Opinion
This case was consolidated with the case of Peter Goralski, Docket No. 29096, for purposes of hearing only. Separate briefs were submitted and it was agreed that the Court would render separate opinions in the cases.
The respondent determined deficiencies in income tax and penalties for the years 1945, 1946, and 1947, as follows:
Year Deficiency Penalty 1945 ........ $3,486.35 $1,743...
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