The Commissioner determined a deficiency of $1,488.02 in income tax and additions thereto of 50 per cent under section 293 (b) for fraud and $206.17 under section 294 (d) (1) (A) and (d) (2) for failure to file a Declaration of Estimated Tax and for substantial understatement of estimated tax, all for 1946. It is conceded that the statute of limitations bars the Commissioner unless the Commissioner proves that the return filed was false and fraudulent with intent to evade...
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