Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined deficiencies in income taxes and penalties, under section 293 (b), Internal Revenue Code of 1939, as follows:
Calendar Year Income Tax Penalty 1946 ........... $ 93.70 $ 46.85 1947 ........... 277.99 138.99 1948 ........... 310.37 155.18 1949 ........... 418.39 209.19
The issues are whether petitioner is...
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