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ESTATE OF WATSON v. COMMISSIONER

Docket No. 108716.

3 T.C.M. 1108 (1944)

Estate of Clarence W. Watson, deceased, Ernest Hutton, as administrator with the will annexed v. Commissioner.

United States Tax Court.

Entered October 20, 1944.

Attorney(s) appearing for the Case

Wood Bouldin, Jr., Esq., for the petitioner. P. A. Bayer, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

LEECH, Judge:

Respondent determined deficiencies in income taxes and a penalty as follows:

                                 Delinquency
  Year               Income Tax    Penalty

  1938 ............  $11,072.91    $2,768.22
  1939 ............   10,902.16    .........
  1940 ............    3,451.72    .........

The penalty depends upon the amount of the deficiency for the calendar year...

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