Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in the income tax of W. W. Dees and Elsie L. Dees in the amounts of $36,972.62 and $88,692.63 for the years 1953 and 1954, respectively, and additions to the tax for 1953 under sections 294(d)(1)(A) and 294(d)(2) of the Internal Revenue Code of 1939 in the respective amounts of $3,646.80 and $2,431.18. For 1955 respondent determined a deficiency in income tax of W. W...
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