Memorandum Findings of Fact and Opinion
RAUM, Judge:
The Commissioner determined deficiencies in income tax against petitioner for the calendar years 1946 and 1947 in the amounts of $3,325.21 and $481, respectively, and penalties in the aggregate amount of $445.06 for petitioner's failure to file a declaration of estimated tax for 1947, as well as for substantial underestimate of estimated tax for 1947. Some of the adjustments giving rise to the determination...
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