Memorandum Findings of Fact and Opinion
ARNOLD, Judge:
The respondent determined deficiencies in petitioners' income and victory tax for 1943 in the amount of $25,125, and in his income tax for 1944 in the amount of $8,623.09. Finding the petitioner's books inadequate to verify his returns, the respondent determined petitioner's income by arbitrarily assuming that he realized a gross profit of 25 per cent for 1942 and 33 1/3 per cent for 1943 and 1944 on...
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