Memorandum Findings of Fact and Opinion
WITHEY, Judge:
Respondent has determined deficiencies in the income tax of petitioners and additions to tax for the years and in the amounts as follows:
Additions to Tax ---------------------------------- Sec. Sec. 294 Sec. 293(a) (d) (1) (B) 6653(a) I. R. C. I. R....
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