Memorandum Findings of Fact and Opinion
OPPER, Judge:
In these consolidated proceedings respondent determined deficiencies in income tax and additions to tax for fraud as follows:
Additions Year Petitioner Tax to Tax 1946 Alvin W. Boettcher $18,273.32 $ 9,136.66 1947 Alvin W. Boettcher 21,925.39 10,962.70 1946 Elsie Boettcher .. 4...
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