Memorandum Findings of Fact and Opinion
The respondent determined a deficiency of $75,408.10 in the petitioners' income tax liability for the year 1944. He also imposed a fraud penalty of $37,704.05 for the same year. He assessed $35,846.41 of the income tax liability and $17,773.21 of the penalty as jeopardy assessments under the provisions of section 273 of the Internal Revenue Code. In his amended answer, the respondent claimed a deficiency of $37,669.28 and...
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