Memorandum Findings of Fact and Opinion
HOYT, Judge:
In his notice of deficiency dated January 18, 1961, the respondent determined income tax deficiencies and additions to the tax against petitioners for the calendar years 1942 through 1956 as follows:
Sec. 293(b), 1939 Year Deficiency Code or Sec. Sec. 6653(b), 294(d)(2) ...
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