Memorandum Findings of Fact and Opinion
TURNER, Judge:
The respondent determined deficiencies in income tax against petitioner for the years 1946 and 1947 in the amounts of $1,309.89 and $2,433.84, additions to tax for the said years for fraud in the amounts of $654.95 and $1,216.92, and a 25 per cent addition to tax of $608.46 for the year 1947, for failure to file a timely return.
The questions for decision are (1) to what extent, if any, the respondent...
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