Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined the following deficiencies in petitioners' income tax and in additions thereto under section 294(d) (1) (A), I. R. C. 1939, and section 6651(a), I. R. C. 1954, for the following taxable years:
Deficiency ------------------------------ Income Sec. 294...
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