Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent has determined deficiencies in income taxes and penalties as follows:
Amount of Deficiencies 5% Year Income Tax Penalty 1946 ................. $ 7,624.90 ....... 1947 ................. 10,570.73 $528.54 January 1-November 17, 1948 ............... 16,811.57 840...
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