Memorandum Findings of Fact and Opinion
Respondent determined deficiencies in income taxes and penalty in the amounts and for the fiscal years set forth below:
Penalty Sec. 294(d)(2) Year Ended Deficiency I. R. C. of 1939 2/28/47....... $ 61,709.74 .......... 2/29/48....... 39,654.79 .......... 2/28/49....... 5,525.12 .............
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