Memorandum Findings of Fact and Opinion
Respondent determined a deficiency in petitioner's income tax liability for the year 1961 in the amount of $1,625.24 and a "Section 6653(b) Penalty" in the sum of $812.62. A copy of the deficiency letter and an accompanying statement is attached to the petition. This statement indicated that petitioner's "taxable income has been computed upon the basis of increase in net worth during the taxable year with adjustment for personal...
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