Memorandum Findings of Fact and Opinion
JOHNSON, Judge:
These proceedings were consolidated for hearing and involve deficiencies and penalties as follows:
Docket No. 35451 1946 1947 1948 1949 Gift Tax ... $5,401.27 $5,129.18 $2,735.72 $1,672.36 Penalty 1,350.32 1,282.30 683.93 418.09
Docket No. 38239 ...
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