Memorandum Findings of Fact and Opinion
Respondent determined deficiencies in the income taxes of petitioner and 50 per cent fraud penalties under section 293(b) of the Internal Revenue Code of 1939, as follows:
Taxable Amount of Deficiencies Year Income Tax 50% Penalty 1940 ........... $ 4,578.43 $ 2,289.22 1942 ........... 22,046.19 11,023...
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