Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The Commissioner determined the following deficiencies in income tax and additions to tax:
Additions to Tax, I. R. C. 1939 Sec. 294 Sec. Year Income Tax (d)(1)(A) 294(d)(2) 1952 ....... $12,104.19 $3,350.16 $987.28
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