Memorandum Opinion
JOHNSON, Judge:
This proceeding involves a deficiency in income tax for the fiscal year ended March 31, 1951. The issue is whether petitioners are liable for a penalty of $952.54 imposed under section 294(d)(2) of the Internal Revenue Code of 1939 for substantially underestimating their estimated tax.
All of the facts are set forth in stipulations of fact which we adopt by reference as our findings of fact.
Petitioners...
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