Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The respondent determined a deficiency of $37,822.16 in the petitioner's income tax for 1946 and an addition to tax under section 294(d)(2) of the Internal Revenue Code of 1939 of $3,874.08 for underestimating tax. The issues presented by the pleadings are the correctness of the respondent's action in determining (1) that a certain deposit of cash in the amount of $22,900 made by petitioner during the...
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