Memorandum Findings of Fact and Opinion
Respondent has determined deficiencies and penalties against petitioner, Raymond S. Whitfield, as follows:
Fraud Negligence Sec. 294(d)(2) Year Tax Deficiency Penalty Penalty Penalty 1944 Income ............. $4,694.78 $2,347.39 $234.74 $278.63 1945 Income ............. 1,807.25 903...
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