Memorandum Findings of Fact and Opinion
BRUCE, Judge:
The respondent determined a deficiency of $11,830.84 in the income tax of petitioners for the taxable year ended December 31, 1948. He further determined that petitioners were liable for an addition to tax in the amount of $81 for failure to pay installments of estimated tax declared, pursuant to section 294(d)(1)(B) of the Internal Revenue Code of 1939. The petition assigned error to the action of the...
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