Memorandum Findings of Fact and Opinion
HARRON, Judge:
The Commissioner determined deficiencies in income tax for 1947 and 1948, to which he made 50 per cent additions for fraud under section 293(b) of the 1939 Code, as follows:
Year Deficiency Sec. 293(b) 1947 ............ $2,426.37 $1,213.19 1948 ............ 2,463.35 1,231.68
The only question to be decided is whether all or part of the deficiency...
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