Memorandum Findings of Fact and Opinion
HARRON, Judge:
The Commissioner has determined deficiencies in income tax for the years 1940 through 1947, inclusive, and he has made 50 per cent additions to the deficiencies under section 293(b), I. R. C. Also, he has added the penalty of 6 per cent to the tax for 1946 and 1947, under section 294(d)(2). The determinations originally made by the respondent were as follows:
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