Memorandum Findings of Fact and Opinion
TRAIN, Judge:
The respondent determined deficiencies in the petitioner's income tax and additions to tax under section 293(b) of the Internal Revenue Code of 1939 as follows:
Addition Year Deficiency to Tax 1944....... $333,911.49 $166,955.75 1945....... 203,538.01 101,769.01
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