Memorandum Opinion
MURDOCK, Judge:
The Commissioner determined deficiencies in income tax for 1940 and 1941, together with penalties, against R. J. Arnett, Alleged Trustee for G. P. Fitzgerald, Nonresident Alien (Docket No. 4589). He also determined deficiencies and penalties in income tax for the same two years against R. J. Arnett, Alleged Agent for Withholding Account of G. P. Fitzgerald, Nonresident Alien (Docket No. 4590). The facts in these two proceedings...
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