Memorandum Opinion
TIETJENS, Judge:
The petitioners filed a joint return for the calendar year 1950 with the collector of internal revenue at Richmond, Virginia.
The respondent determined a deficiency in income tax of $1,006.75 and an addition to the tax of $882.78 pursuant to section 294(d)(2), Internal Revenue Code of 1939, for substantial underestimate of estimated tax. The petition alleges error only with reference to the assertion of the addition...
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