Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
Petitioner reported net income on his original returns for the calendar years 1938 and 1939, of $22,951.74, and $8,492.97, respectively. In January 1944, after respondent had commenced an investigation of petitioner's returns for 1938 and 1939, petitioner filed amended returns for those years reporting additional income. Respondent asserted deficiencies for those years upon determining that petitioner...
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