Memorandum Findings of Fact and Opinion
PIERCE, Judge:
This case involves deficiencies in income tax and additions to tax for fraud, which the Commissioner determined on June 8, 1962, in respect of the 1950, 1951 and 1952 income taxes of Edward E. McLean, deceased, and his widow Edna R. McLean. Because these taxpayers had filed a joint income tax return for each of the said years, the joint statutory notice of deficiencies was mailed to the above-named petitioners...
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