Memorandum Findings of Fact and Opinion
The respondent determined deficiencies of $150,523.36 and $145,563.89 in the income taxes of the petitioner for the years 1936 and 1937, respectively. He also imposed fraud penalties of $75,261.68 and $72,781.95 for the same respective years.
The case was originally heard by the Board of Tax Appeals on February 23, 1942. The issues there presented were:
(1) Whether or not the petitioner had understated his...
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