Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
Respondent determined deficiencies in income tax and penalties as follows:
Fraud Delinquency Year Deficiency Penalty Penalty 1945......... $2,470.16 $1,235.08 ....... 1946......... 4,203.87 2,101.94 ....... 1947......... 6,844.40 3,422.20 ....... 1948......... 937.88 468.94 ...
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