Memorandum Findings of Fact and Opinion
HARRON, Judge:
The Commissioner determined deficiencies in income tax for 1947, 1948, and 1949, and a 25 per cent penalty under section 291(a) of the 1939 Code for 1947, as follows:
Year Deficiency Sec.291(a) 1947 ............... $ 112.00 $28.00 1948 ............... 2,296.32 -0- 1949 ............... 268.00 -0- _________...
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