ALLEN, Circuit Judge.
This is a petition to review determinations of deficiency for taxable years 1949 and 1950, for which petitioner and his wife filed joint returns. The Commissioner determined a deficiency of $53,476.18 against petitioner, who owned and operated a race wire service and a racing stable and also placed extensive individual bets on horse races. The Tax Court reduced the Commissioner's determination to not less than $40,150 for 1949. Penalties determined...
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