Memorandum Findings of Fact and Opinion
The Commissioner determined that an addition to the tax for 1948 in the amount of $1,493.63 was due under section 294(d) (2) of the Internal Revenue Code because of a substantial understatement of Declaration of Estimated Tax. The issues for decision are whether this addition to the tax can be avoided by a showing that the understatement was due to reasonable cause and not...
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