Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined deficiencies in the income tax liabilities of petitioners and an addition to tax as follows:
Addition to Fiscal year tax Sec. Docket ending 294(d)(2), No. August 31 Deficiency I.R.C. 1939 71689 1951 $ 31,601.71 1952 85,156.54 ...
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