Memorandum Findings of Fact and Opinion
TURNER, Judge:
The respondent determined the following deficiencies in income tax and additions to tax for fraud against petitioner as follows:
Year Deficiency Additions under Sec. 293(b), I.R.C. of 1939 1942 .............. $5,209.32 $2,604.66 1943 .............. 6,963.20 5,965...
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