Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined deficiencies in petitioner's income tax liability and imposed delinquent filing penalties as follows:
Tax Period Deficiency Penalty 3/12/47 to 1/31/48 ... $23,263.05 (25%) $5,815.76 2/ 1/48 to 1/31/49 ... 1,223.88 (10%) 122.39
The questions presented are whether petitioner was an exempt charitable corporation...
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