Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined deficiencies in income tax and penalties against petitioner as follows:
Penalties Year Income Tax Sec. 294(d) Sec. 291(a) 1945 ...... $2,380.11 $595.03 1946 ...... 1,680.46 420.10 1947 ...... 1,562.46 ..... 1948 ...... ...
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