Memorandum Findings of Fact and Opinion
Respondent has determined a deficiency of $11,983.02 in petitioner's income tax liability for its fiscal year ended May 31, 1961, and a penalty under section 6653(b), Internal Revenue Code of 1954, in the amount of $6,371.44, the latter figure being explained as "50% of ($18,279.97 [the income tax liability as corrected] less $5,537.10 [the income tax liability shown on return])."
Respondent's determination is based...
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