Memorandum Findings of Fact and Opinion
The Commissioner has computed petitioners' income for the taxable years 1945 through 1948 pursuant to the so-called "net worth increase" method and has determined the following income tax deficiencies and penalties for those years:
50% Fraud Year Deficiency Penalty 1945 .............. $1,725.31 $1,317.36 1946 .............. 832.33 416...
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