Memorandum Findings of Fact and Opinion
Respondent determined deficiencies in income taxes and additions to the tax under section 294(d)(1)(A) and 294(d)(2), Internal Revenue Code of 1939, of the petitioners as follows:
Section Section 294(d)(1)(A) 294(d)(2) Year Deficiency Addition Addition 1949...... $ 38.00 1950...... 4,640.10 $560.27...
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