Memorandum Findings of Fact and Opinion
This proceeding involves a deficiency in income tax for the year 1944 of $34,059.44 and a penalty of $8,514.86, asserted under section 291 of the Code.
The issues to be determined are: (1) did Daniel Ryweck (hereinafter referred to as the petitioner) receive taxable income of $58,839.03 in 1944; and (2) did respondent err in asserting a 25 per cent penalty for petitioner's failure to file a Federal income tax return...
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