Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The Commissioner determined the following deficiencies in income tax:
Docket Additions No. Year Deficiency to tax 46721 1947 .......... $23,081.11 46722 1947 .......... 10,389.96 1948 .......... 13,211.75 Section 294 ...
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