Memorandum Opinion
OPPER, Judge:
Respondent determined deficiencies in tax, and in additions thereto for fraud, and under section 294(d), Internal Revenue Code of 1939, as follows:
Additions Calendar Additions under Year Income Tax for Fraud Sec. 294(d) 1949 ........ $ 6,692.68 $ 3,447.95 $1,403.09 1950 ........ 10,792.94 5,396.47 2,062.75 ...
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