Memorandum Findings of Fact and Opinion
KERN, Judge:
Respondent determined deficiencies in additions to the tax in a total amount of $5,467.42 in connection with the determination of petitioner's income tax liability for the taxable years ended December 31, 1951, and December 31, 1952. These deficiencies in additions to tax included an addition to tax for failure to file declaration of estimated tax within the time prescribed under section 294(d)(1)(A)
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