Memorandum Findings of Fact and Opinion
HARRON, Judge:
The Commissioner determined a deficiency in income tax of $25,876.27 for the year 1947, to which he added 50 per cent under section 293(b) of the Code, $12,938.14. In the absence of accounting records disclosing true income for 1947, the Commissioner computed net income upon the basis of increase in net worth during 1947 plus estimated living expenses, plus expenditures held to be not deductible. Vernon...
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