Memorandum Findings of Fact and Opinion
FISHER, Judge:
The respondent determined deficiencies in income tax of petitioner and additions thereon for fraud under section 293(b), Internal Revenue Code as follows:
50% Fraud Year Deficiency Penalty 1944............. $19,138.89 $ 9,569.44 1945............. 13,903.74 6,951.87 1946............. 14,176.72 7...
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