Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined deficiencies in income tax and additions to tax for fraud, failure to file a timely return, failure to file declarations of estimated tax, and substantial underestimation of estimated tax, as follows:
1945 1946 Deficiency in tax ............ $371.62 $ 83.60 Additions under section 293(b) 185.81 41.80 Addition...
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