Memorandum Findings of Fact and Opinion
ARUNDELL, Judge:
Respondent determined deficiencies in income tax under the 1939 Code for the calendar years 1952 and 1953, under the 1954 Code for the year 1954, and additions to tax under the 1939 Code as follows:
Additions under Section Year Deficiency 294(d)(1)(A) 294(d)(2) 1952 ......... $43,026.31 $3,969.72 $2,646.48 1953 .........
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