Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The respondent determined deficiencies in the income tax of the petitioners and additions to tax under sections 293(a), 294(d)(1)(A) and 294(a)(2) of the Internal Revenue Code of 1939 as follows:
Additions to tax --------------------------------- Deficiency Sec. Sec. 294 Sec. 294 Year ...
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