Memorandum Opinion
ATKINS, Judge:
The respondent determined deficiencies in income tax against the petitioner for the years 1951 and 1952 in the amounts of $12,723.49 and $2,348.76, respectively, and an addition to the tax for the year 1952 in the amount of $394.14 for substantial underestimation of estimated tax. The only issue, aside from the addition for underestimation, is whether amounts received by the petitioner in each year from the former employers...
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