LOW v. COMMISSIONER

Memorandum Findings of Fact and Opinion

These consolidated proceedings involve deficiencies in income tax and penalties asserted against Mon Low (hereinafter referred to as the petitioner) and his wife, Quan Suey Hing, as follows:

                                  50%          25%
  Year          Deficiency      Penalty      Penalty

  1944........  $ 5,790.70    $ 2,895.35         None
  1945........   53,149.46     26,574.73         None
  1946...

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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