Memorandum Findings of Fact and Opinion
JOHNSON, Judge:
Respondent determined a deficiency in petitioner's income tax for the year 1948 in the amount of $635.69, and penalties under section 294 (d) (1) (A), I. R. C., for failure to file declaration in the amount of $63.57, and under section 294 (d) (2) for substantial underestimate of estimated tax in the amount of $38.14.
The issues are: (1) Did petitioner under-state his income on his 1948 return...
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