Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined deficiencies in petitioner's income tax for the years 1946 and 1947 in the amounts of $20,733.42 and $778.34, respectively, and additions to tax under section 293(b), I. R. C. 1939, in the amounts of $12,154.93 and $389.17, respectively.
The issues are (a) whether any part of the deficiencies for the years 1946 and 1947 is due to fraud with intent to evade tax under section...
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