Memorandum Findings of Fact and Opinion
JOHNSON, Judge:
This proceeding involves deficiencies in income tax and penalties for the calendar years 1946, 1947 and 1948.
Petitioners filed separate returns on the community property basis for 1946 and joint returns for 1947 and 1948. The deficiency letter for the taxable year ended December 31, 1947, was directed to Robert E. Rushing and Mrs. Robert E....
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