Memorandum Findings of Fact and Opinion
OPPER, Judge:
By these proceedings petitioner seeks a redetermination of deficiencies in income tax for 1941, 1942, and 1943. Respondent has determined a 50 per cent fraud penalty for each of those years. Petitioner also claims an overpayment for 1941 and 1943. The amounts involved are as follows:
Year Deficiency 50% Penalty Overpayment Asserted ...
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