Memorandum Findings of Fact and Opinion
RAUM, Judge:
The Commissioner determined deficiencies in income tax for the years 1947 and 1948 against petitioners and added 50 per cent for fraud in accordance with Section 293 (b) of the Internal Revenue Code, as follows:
Year Deficiency Addition for fraud 1947...... $12,641.58 $6,320.79 1948...... 11,002.62 5,501.31
Petitioners are husband and wife and reside...
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