Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The respondent determined deficiencies in income tax for 1943 and 1944 in the respective amounts of $7,563.80 and $9,231.50, and 50 per cent fraud penalties in the respective amounts of $3,781.90 and $4,615.75. At the hearing the petitioner conceded liability for the deficiencies in tax, but contests the assertion of the fraud penalties. The returns for the calendar years 1943 and 1944 were filed with...
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