Memorandum Findings of Fact and Opinion
OPPER, Judge:
By this proceeding petitioner seeks a redetermination of deficiencies in income tax and penalties for failure to file returns, in the following amounts for the taxable years 1937 to 1940:
Deficiency Penalty 1937 ................ $299.79 $ .... 1938 ................ 285.86 71.47 1939 ................ 60.54 15.14 1940 ........
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