Memorandum Findings of Fact and Opinion
ARNOLD, Judge:
Petitioners contest income tax deficiencies and a 50 percent fraud penalty thereon asserted against them for the years 1936 and 1937. The amounts in issue are as follows:
Year Deficiency 50% Penalty 1936 .............. $ 479.98 $ 239.99 1937 .............. 4,148.29 2,074.15 __________ _________ ...
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