Memorandum Findings of Fact and Opinion
HARRON, Judge:
The respondent determined a deficiency in income tax for 1944 in the amount of $7,024.10. The respondent has made claim in his amended answer for the 6 per cent addition to the tax under section 294 (d) (2) of the Code in the amount of $421.45; and for addition to the deficiency either under section 293 (b), for fraud, in the amount of $3,512.05, or, in the alternative, under section 293 (a) for negligence...
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