Memorandum Findings of Fact and Opinion
The Commissioner has computed petitioner's income for the taxable years 1946, 1947, and 1948 by application of the so-called "net worth increase" method. He has determined deficiencies in petitioner's income taxes for those years and has added negligence penalties, as follows:
5% Negligence Year Deficiency Penalty 1946 ............. $ 570.54...
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