Memorandum Findings of Fact and Opinion
FISHER, Judge:
Respondent determined deficiencies in income tax and additions to tax under sections 293(b), 294(d)(2) and 294(d)(1)(A), with respect to Peter Meyer, and deficiencies in income, declared value excess profits and excess profits taxes, and additions to tax under sections 293(b) and 291(a) with respect to Fifth Avenue Specialties, Inc. as follows:
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