NAPUCHE v. COMMISSIONER

Memorandum Findings of Fact and Opinion

HARRON, Judge:

The respondent determined deficiencies in income tax for the years 1946-1951, inclusive, 50 per cent additions to the deficiencies under section 293 (b), 1939 Code, and an addition to tax for 1948 under section 291(a) as follows:

  Year         Deficiencies  Sec. 293(b)  Sec. 291(a)

  1946.......    $7,594.97    $3,259.40        None
  1947.......     8,089.70     4,044.85        None...

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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