Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The respondent determined additions to the tax for 1952 in the amount of $2,203.38 for failure to file a declaration of estimated tax and of $1,468.93 for substantial underestimation of estimated tax. The sole issue is whether both additions may be imposed concurrently. The petitioners' return for 1952 was filed with the director of internal revenue at Jacksonville, Florida. The facts are found as...
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