United States Tax Court.
Memorandum Findings of Fact and Opinion
JOHNSON, Judge:
This proceeding involves deficiencies in income tax and penalties as follows:
Year Deficiency 5% Penalty 1948...... $ 8,726.47 $436.32 1949...... 12,621.56 631.08
The issues are whether the respondent erred in increasing the amount of income realized as commissions from sales of notes, and in imposing negligence penalties under section 293(a), I. R....
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