Memorandum Findings of Fact and Opinion
This proceeding involves a deficiency in income tax for the years and in the amounts as follows:
Taxable Year Income Tax 1937 $ 1,549.49 1938 14,663.84
Two questions are presented: (1) Whether petitioner is estopped by the judgment in the case of Ward Kremer, Docket No. 105838, entered April 20, 1942 [Dec. 12,505-A], from asserting in the instant proceeding...
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