Memorandum Opinion
VAN FOSSAN, Judge:
The Commissioner determined deficiencies in income tax and additions to tax (penalties), as follows:
50% 25% Year Deficiency Penalty Penalty 1938 .... $ 2,219.80 $ 1,109.90 None 1939 .... 23,323.94 11,661.97 None 1940 .... 94,182.14 47,091.07 None...
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