Memorandum Opinion
BRUCE, Judge:
The Commissioner determined deficiencies in income tax and additions to tax under section 293(b), Internal Revenue Code of 1939, as follows:
Addition to Tax Sec. 293(b) Year Deficiency I. R. C. 1939 1946......... $18,078.09 $9,039.05 1947......... 10,282.02 5,141.01
The decedent, Charles W. Drahmann...
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