Memorandum Findings of Fact and Opinion
HARRON, Judge:
The Commissioner determined deficiencies in income tax for the years 1944 and 1945, and he increased the deficiencies by 50 per cent under section 293(b) of the Code as follows:
Year Deficiency Sec. 293(b) 1944 ............. $130.131.90 $65,065.60 1945 ............. 147,424.58 73,712.29
The petitioner does not contest the determinations...
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