Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined deficiencies in petitioners' income tax for the years 1953 and 1954 in the amounts of $660 and $18,454, respectively, and an addition to tax for the year 1954 under section 294(d)(2) of the 1939 Code, in the amount of $1,094.76. The year 1955 is involved only because we must determine the amount of the net operating loss for the year 1955 which may be carried back to 1953 and 1954...
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