Memorandum Opinion
VAN FOSSAN, Judge:
Respondent determined a deficiency of $10,243.29 in income tax of petitioner for the calendar year 1950 and added thereto a penalty of 25 per cent ($2,560.82) for failure to file a return for such year. Petitioner concedes the correctness of the deficiency and contests only the penalty, contending its action in failing to file was "due to reasonable cause and not due to willful neglect", section 291, I. R. C.
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