Memorandum Findings of Fact and Opinion
ARUNDELL, Judge:
Respondent determined deficiencies in income tax and additions to the tax under section 293(b) of the Internal Revenue Code of 1939 against the original petitioner, E. C. Lloyd, for whom his estate, represented by Mary Elizabeth Lloyd, executrix under the will of E. C. Lloyd, deceased, has been substituted as petitioner, for the calendar years 1943 through 1947, as follows:
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