BRATCHER v. COMMISSIONER

Memorandum Findings of Fact and Opinion

OPPER, Judge:

By this proceeding petitioner challenges respondent's determination of deficiencies in income tax and assessment of penalties for failure to file a timely return and for fraud for the years 1941, 1942, and 1943, as follows:

                            25%         50%
Year        Deficiency    Penalty     Penalty       Total

1941......   $2,683.73    $670.93    $1,341.87    $4,696.53
1942...

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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