Memorandum Findings of Fact and Opinion
MULRONEY, Judge:
The respondent determined deficiencies and additions to tax against the petitioner for the taxable year 1954, as follows:
Additions to the Tax Sec. 294 Sec. 294 (d)(1)(A), (d)(2), Taxable I. R. C. I. R. C. Year Deficiency 1939 1939 1954.......
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