Memorandum Opinion
RAUM, Judge:
This case involves deficiencies in income tax for the years 1946, 1947, and 1949, plus statutory additions as follows:
50% 25% Year Deficiency Penalty Penalty 1946 ........... $642.89 $321.45 $160.72 1947 ........... 438.00 219.00 ...... 1949 ........... 406.72 203.36 ......
The Government...
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