Memorandum Findings of Fact and Opinion
WITHEY, Judge:
Deficiencies in income tax and additions to tax of the petitioner have been determined by respondent for the following taxable years and amounts:
Additions to Tax ---------------------------- Sec. Sec. 294(d) (1) (A) 294(d) (2) Year Deficiency I. R. C. 1939 I....
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