Memorandum Findings of Fact and Opinion
OPPER, Judge:
Petitioners appeal from the following determination of deficiencies in income taxes and assertion of 50 per cent fraud penalties for the calendar years 1942, 1943, 1944 and 1945:
Deficiency Year Income Tax Penalty 1942 ............ $ 3,142.29 $ 1,571.15 1943 ............. 17,974.74 8,911.05 1944 ............. 44,992.61 22,496.31 January...
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