This proceeding involves a determination by the Commissioner of a deficiency and additions to tax in the joint and several income tax liability of petitioner Alma Helfrich and her former husband, Carl W. Helfrich, for the year 1947 in the following amounts:
Deficiency Addition to tax sec. 293 (b) Addition to tax sec. 294 (d) (1) (A) $118,353.87 ...
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