Memorandum Findings of Fact and Opinion
BRUCE, Judge:
The respondent determined a deficiency of $9.54 in the income tax of petitioners for the taxable year 1950 which petitioners do not contest. He further determined that petitioners were liable for an addition to tax in the amount of $277.50 for failure to file a declaration of estimated tax for 1950. The only question is whether petitioners are liable for the addition to tax.
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