Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The respondent has determined deficiencies in the income tax of the petitioner and additions to tax for fraud under section 293(b) of the Internal Revenue Code as follows for the indicated years:
Additions Year Income tax to tax 1945 ............ $ 7,233.66 $3,616.83 1946 ............ 13,411.61 6,705.80...
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