Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined deficiencies in income taxes and additions to taxes for fraud and failure to file returns as follows:
Additions Additions to Tax for Calendar Income to Tax Failure to Year Tax for Fraud File Return 1946 .... $6,977.47 $3,488.74 $1,297.67 1947 .... 8,077.87 4...
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