Memorandum Findings of Fact and Opinion
ATKINS, Judge:
The respondent determined a deficiency of $5,505.28 in income tax for the year 1951. He also determined that petitioners were liable for additions to tax under section 294(d) of the Internal Revenue Code of 1939 in the amounts of $473.89 and $900.50 for the years 1950 and 1951, respectively.
The principal issue presented for decision is whether the respondent erred in determining that the petitioner...
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