Memorandum Findings of Fact and Opinion
In these proceedings the respondent determined a deficiency in the income tax of the decedent and Josephine Santuccio for the calendar year 1943 in the amount of $2,378.16 to which he added a 50 per cent penalty in the amount of $1,189.08.
The petitioners allege error in the respondent's determination of the amount of income realized by the decedent from a partnership and in his addition of a fraud penalty. The pleadings...
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