Memorandum Findings of Fact and Opinion
JOHNSON, Judge:
Respondent has determined deficiencies in petitioner's income tax and penalties as follows:
Sec. Sec. 294 Sec. 294 293(b) (d)(1)(A) (d)(2) Year Deficiency Penalty Penalty Penalty 1946 .... $ 3,458.34 $ 2,434.24 $536.84 ...... 1947 .... 40,245.36 20,122.68 ...... $2,518.49 ...
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