Memorandum Findings of Fact and Opinion
ATKINS, Judge:
The respondent, on February 24, 1956, mailed deficiency notices to the petitioner John J. Finnorn for the years 1945 to 1947 and to him and the petitioner Natalie Finnorn for the years 1948 to 1951, setting forth the following deficiencies in income tax and additions to tax:
Additions to Tax, I. R. C. 1939 ...
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