Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined deficiencies and delinquency penalties in petitioners' income tax liability for the years 1946 through 1949 as follows:
Delinquency penalties under Year Deficiency section 291(a) 1946 ........... $110.19 $ 58.64 1947 ........... 56.41 87.36...
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