Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined deficiencies in petitioner's income taxes for the years 1942 through 1946 in the total amount of $72,239.85 and fraud penalties as follows:
Fraud Year Penalties 1942 ................. $ 887.35 1943 ................. 3,229.32 1944 ................. 14,345.94 1945 ................. 6,792.73 1946...
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