Memorandum Findings of Fact and Opinion
The respondent determined deficiencies in income tax and additions thereto of petitioners for the years 1949, 1950, and 1951, as follows:
Sec. Sec. Sec. Year Deficiency 293(b) 294(d)(1)(A) 294(d)(2) 1949 ............... $ 38,509.94 $ 19,254.97 $ 4,438.72 $ 2,663.22 1950 ............... 236,930.36 ...
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