Memorandum Findings of Fact and Opinion
OPPER, Judge:
On motion of respondent these two proceedings — Docket No. 97390 and Docket No. 97391 — were consolidated. In the first proceeding the following deficiencies were determined and fraud penalties claimed:
Year Deficiency Fraud Penalties 1927 ....... $ 86,715.01 $ 43,357.51 1928 ....... 78,810.24 39,405.12 1929 ....... 238,416.24...
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