Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined deficiencies in income tax and additions to tax of G. Arthur Pershall and Merceda C. Pershall, husband and wife, as follows:
Additions to tax Sec. Sec. Year Deficiency 293(b) 294(d) 1950 ........... $906.92 $453.46 $60.90 1952 ........... 823.11...
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