Memorandum Findings of Fact and Opinion
FISHER, Judge:
This proceeding involves deficiencies in income tax and additions to tax determined against petitioner as follows:
Additions to Tax, I. R. C. 1939 Sec. Sec. 294 Year Deficiency 293(b) (d)(2) 1946........ $128,259.62 $64,129.81 $7,701.79 1947........ 544...
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