Memorandum Findings of Fact and Opinion
HARRON, Judge:
The Commissioner determined a deficiency in income and victory tax for the year 1943 in the amount of $1,025.46. The Commissioner has added to the deficiency a 5 per cent penalty in the amount of $51.27, under section 291(a) of the Internal Revenue Code, for failure to file the income tax return within the time prescribed by law. The amount of the penalty is 5 per cent of the amount of the deficiency...
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