Memorandum Findings of Fact and Opinion
This proceeding involves a deficiency in additions to the tax under section 294 of the Internal Revenue Code of 1939 for each of the years 1952 and 1953, as follows:
Additions to the Tax Under Sec. 294 Sec. 294 Year Deficiency (d)(1)(A) (d)(2) 1952 ............ ......
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