Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The Commissioner determined the following deficiencies in income tax and additions to tax for negligence under Section 293(a):
5% Addition to Tax Year Deficiency for Negligence 1946 ............ $9,515.06 $475.75 1947 ............ 397.40 533.78 1948 ....
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