Memorandum Findings of Fact and Opinion
TURNER, Judge:
The respondent determined deficiencies in income tax and additions to tax under section 294(d)(2) of the Internal Revenue Code of 1939 against the petitioners as follows:
Addition Year Deficiency to Tax 1951 .......... $ 755.00 $ 55.85 1952 .......... 6,642.40 382.81...
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