Memorandum Findings of Fact and Opinion
On February 11, 1955, respondent determined that petitioner's "income tax liability for the taxable years ended December 31, 1940 to December 31, 1947, inclusive, disclosed deficiencies in tax aggregating $1,718,237.69 and penalties aggregating $1,552,767.47 * * *." Specifically, the deficiencies, additions to tax under section 293(b) of the Internal Revenue Code of 1939, additions to tax under section 291(a), and additions...
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