Memorandum Findings of Fact and Opinion
Respondent determined deficiencies in income tax of petitioner and additions thereto for fraud for the years 1946 and 1947 and an addition thereto for failure to file a return for the year 1947, as follows:
50 Per 50 Per Cent Cent Year Tax Deficiency Penalty Penalty 1946... Income $ 2,559.74 $ 1,279.87 .......
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