Memorandum Findings of Fact and Opinion
TRAIN, Judge:
Respondent determined a deficiency in petitioner's income tax for the calendar year 1956 in the amount of $1,269.47 with additions to tax under section 6651 of the 1954 Code in the amount of $317.37.
The issues for decision are as follows:
(1) Whether petitioner is liable for the addition to tax under section 6651, 1954 Code, for failure to file a timely return;
(2) Whether the...
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