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ESTATE OF WINN v. COMMISSIONER

Docket No. 36869.

12 T.C.M. 886 (1953)

Estate of John P. Winn, Deceased, Ruth J. Winn, Executrix, and Ruth J. Winn, Individually, v. Commissioner.

United States Tax Court.

Entered July 31, 1953.

Attorney(s) appearing for the Case

Ed M. Lowrance, Esq., 81 Monroe Avenue, Memphis, Tenn., John R. Stivers, Esq., and Walter Chandler, Esq., for the petitioners. Charles R. Hembree, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

JOHNSON, Judge:

Respondent determined in his notice of deficiency that petitioners are liable for the 50 per cent fraud penalty based upon income tax deficiencies for the years 1943, 1944 and 1945 as follows:

  Year                50% Fraud Penalty
-----------------------------------------
  1943 ...............    $1,232.36
  1944 ...............     1,471.58
  1945 ...............     1,966.90
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