Memorandum Findings of Fact and Opinion
HARRON, Judge:
The respondent determined deficiencies in income tax for the years 1946-1951, inclusive, 50 per cent additions to the deficiencies under section 293 (b), 1939 Code, and an addition to tax for 1948 under section 291(a) as follows:
Year Deficiencies Sec. 293(b) Sec. 291(a) 1946....... $7,594.97 $3,259.40 None 1947....... 8,089.70 4,044.85 None...
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