Memorandum Findings of Fact and Opinion
JOHNSON, Judge:
This proceeding involves deficiencies in income tax for the years 1949 and 1950 in the amounts of $3,026.89 and $5,437.03, respectively, and an addition to income tax under section 294(d)(2) of the 1939 Code in the amount of $886.53. Respondent concedes that the penalty imposed under section 294(d)(2) was erroneously imposed.
The issues are whether certain payments made by petitioner to his...
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