The respondent determined a deficiency in income tax against the petitioner for 1945 of $788.31 and a 50 per cent addition to tax for fraud of $1,088.65. The apparent discrepancy as to amounts is brought about by the fact that the deficiency of $788.31 as determined is after allowance for tax withheld by petitioner's employer and $400 paid on the basis of estimated tax, the $1,088.65 being 50 per cent of the difference between the tax reported by petitioner on his return...
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