Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
This proceeding involves income tax deficiencies and penalties in the amounts and for the calendar years, as follows:
5% Negligence Penalty Income Tax Under Sec. Year Deficiency Penalty 294, IRC 1946 ...... $8,741.10 $437.06 $483.55 1947 ...... 529.76 26.40 92...
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