Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined deficiencies in income taxes and penalties against petitioner as follows:
----------Amounts---------- Penalty (Sec. 293(b) Year Tax I.R.C. of 1939) 1943 ........ $ 32,234.63 $ 16,169.07 1944 ........ 204,933.92 102,466.96...
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