The Commissioner has determined a deficiency of $2,459.67 in petitioner's income tax for the year 1945 and a penalty of $247.75 for "substantial underestimation of estimated tax." The deficiency results from the addition to the $7,802.73 net income reported on the income tax return of Lester O. Stearns of: (a) Contract settlement payment, $6,129.04; and (b) medical expense, $306.45. These adjustments are explained in the deficiency notice as follows:
(a) The settlement...
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