Memorandum Findings of Fact and Opinion
ATKINS, Judge:
The respondent determined deficiencies in income tax and an addition to tax as follows:
Addition to Tax Year Income Tax Section 294(d)(2) Fiscal Year Ended Oct. 31, 1953 ........... $1,736.16 $68.13 Fiscal Year Ended Oct. 31, 1954 ........... 1,594.65 ...
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