Memorandum Findings of Fact and Opinion
This case was consolidated with the case of Mathew Goralski, Docket No. 29098, for the purpose of hearing only. Separate briefs were submitted, and it was agreed that the Court would render separate opinions in the cases.
The respondent determined deficiencies in income tax and penalties for the years 1946 and 1947 as follows:
Years Deficiencies Penalties 1946 ........$1,658.57 $829.28...
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