Memorandum Opinion
RICE, Judge:
This proceeding involves a deficiency in income tax and penalties determined by the respondent against petitioners for the year 1950 as follows:
Deficiency Sec. 294(d)(1)(A) Penalty Sec. 294(d)(2) Penalty $153.58 $540.06 $355.94
The petitioners concede that the respondent's determination of the deficiency is correct but contest the penalties imposed.
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