Memorandum Findings of Fact and Opinion
DISNEY, Judge:
This case involves income tax for the calendar year 1945. Deficiency was determined in the amount of $477.28. The respondent asserts the 5 per cent negligence penalty under Section 293(a), Internal Revenue Code. The only issue presented is whether the Commissioner erred in disallowing deductions claimed, as follows: For contributions $433.20, interest $493...
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