Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioner's income tax for the calendar year 1952 in the amount of $111,943.46 and additions to tax under section 293(b), I. R. C. 1939 and section 294 (d)(2), I. R. C. 1939, in the amounts of $55,971.73 and $6,686.61, respectively. By amendment to answer filed at the trial respondent alleged that he erred in determining these deficiencies on the basis of petitioner...
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