Memorandum Opinion
ARUNDELL, Judge:
Respondent determined a deficiency in income tax of $1,062.12 for the calendar year 1951, together with additions to income tax under section 294(d)(1)(A) and 294(d)(2) of the Internal Revenue Code of 1939 of $190.80 and $114.48, respectively.
The only issue is whether the respondent erred in determining the addition under section 294(d)(2).
Petitioners are individuals (husband and wife) residing in Stockton...
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