Memorandum Findings of Fact and Opinion
TRAIN, Judge:
Respondent determined deficiencies in income tax and additions to tax of the petitioners for the calendar years 1945 through 1954 as follows:
Additions to Tax 1939 Code 1954 Code Year Deficiency Sec. Sec. 294 Sec. 293(b) (d)(1)(A) 6653(b) 1945 .... ...
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