Memorandum Findings of Fact and Opinion
OPPER, Judge:
In these consolidated proceedings, respondent determined deficiencies in income taxes and penalties as follows:
Docket 294(d) No. Year Deficiency Penalty 42552 1944 ....... $ 4,012.39 ...... 1945 ....... 1,893.14 $ 93.44 1946 ....... 53,584.17 ...... 1947 ........
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