Memorandum Findings of Fact and Opinion
HARRON, Judge:
The Commissioner determined deficiencies in income tax in Docket Nos. 48587 and 48588 for the years 1944 to 1946, inclusive, and added 50 per cent penalties to the deficiencies under section 293(b) of the 1939 Code as follows:
Docket No. 48587, Samuel Liebenson: Year Deficiencies Sec. 293(b) 1944 ........... $1,632.28 $ 816.14 1945 ........
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