KLEINMAN v. COMMISSIONER

Memorandum Findings of Fact and Opinion

BRUCE, Judge:

In these consolidated cases the respondent determined deficiencies in the income tax of petitioners and additions to tax under section 293(b), Internal Revenue Code of 1939, for fraud, under section 294(d)(1)(A) for failure to file declaration of estimated tax, and under section 294 (d)(2) for substantial underestimate, as follows:

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