Memorandum Findings of Fact and Opinion
Respondent determined additions to petitioners' Federal income tax for the year 1951 under sections 294(d)(1)(A) and 294 (d)(2), Internal Revenue Code of 1939, in the respective amounts of $181.04 and $120.70 "for failure to file a declaration of estimated tax and for substantial underestimate of estimated tax."
Findings of Fact
Petitioners, who are husband and wife, live in Torrington, Connecticut, and filed...
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