Memorandum Findings of Fact and Opinion
In this case the respondent has determined a deficiency in petitioners' Federal income tax for the year 1952 in the amount of $2,489.10, an overassessment of petitioners' Federal income tax for the year 1951 in the amount of $2,337.08, and additions to tax pursuant to sections 294 (d)(1)(A) and 294(d)(2), as follows:
Sec. 294 Sec. Year (d)(1)(A) 294(d)(2) 1951...
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