Memorandum Findings of Fact and Opinion
HARRON, Judge:
The Commissioner determined that the petitioners' original income tax return for the year 1944 disclosed a deficiency of $21,040.27, and added the 50 per cent addition thereto for fraud, in the amount of $10,520.14, as provided by section 293 (b) of the Internal Revenue Code.
As a result of the filing of amended returns by the petitioners prior to the issuance of the deficiency notice by the...
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