Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
This proceeding involves deficiencies in income tax for 1946, 1947, and 1948, and penalties asserted for negligence and delinquency. The petitioner filed a return for 1947 but failed to file returns for 1946 and 1948. Her records were inadequate and the dispute concerns the proof of income and expenses. After the case was at issue the respondent, by amended answer, claimed increased deficiencies. At...
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