Memorandum Findings of Fact and Opinion
JOHNSON, Judge:
This proceeding involves deficiencies in income tax in the amounts of $53,177.58 and $11,804.06 for 1946 and 1947, respectively, and a penalty of $26,588.79 under section 293(b), I. R. C. of 1939, for 1946. The issues raised by the pleadings and not settled by stipulation are:
(1) The amount of petitioner's opening inventory in 1946 for (a) lumber, and (b) merchandise;
(2) The amount...
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