Memorandum Findings of Fact and Opinion
HARRON, Judge:
The Commissioner determined a deficiency in income tax in the amount of $110,151.70 for the fiscal year ended April 30, 1945, to which he added a 5 per cent negligence penalty, in the amount of $5,507.59, under the provisions of section 293(a) of the 1939 Code. The questions to be decided are whether the respondent properly increased the amount of sales of petitioner's business by use of a 35 per cent...
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