OPINION.
MURDOCK, Judge:
The Commissioner determined for 1950 an addition to income tax of $696.17 under section 294 (d) (2) of the Internal Revenue Code of 1939, for substantial underestimate of estimated tax and an addition of $1,044.25 under section 294 (d) (1) (A) for failure to file declarations of estimated tax. The facts have been stipulated.
The petitioners have made no showing that their failure to file declarations of estimated tax...
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