Memorandum Finding of Fact and Opinion
This proceeding involves a deficiency in income tax for the year 1947 of $11,246.99 and a penalty, as provided by section 293(b) of the Internal Revenue Code of 1939, of $5,623.50 determined against Spencer D. Lorton (hereinafter referred to as the petitioner). On October 19, 1951, pursuant to section 273(c) of such Code, the respondent made a jeopardy assessment against petitioner for the amount of the deficiency and penalty...
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