Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The respondent determined deficiencies in the petitioners' income tax and addition to tax under section 294 (d)(2) of the Internal Revenue Code of 1939 as follows:
Addition Fiscal year ended Deficiency to tax April 30, 1949........ $3,070.28 ....... April 30, 1950........ 3,921.28 ........ April 30, 1951...
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