Memorandum Findings of Fact and Opinion
Respondent determined deficiencies in income tax for the taxable years 1938 through 1943, plus fraud penalties for each of the years 1938 through 1942, against the petitioner Joseph S. Fay as follows:
Year Deficiency 50% Penalty 1938 .............. $88,454.96 $44,227.48 1939 .............. 66,571.28 33,285.64 1940 .............. 55,152.97 27,576.48 1941 .................
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