Memorandum Findings of Fact and Opinion
Respondent determined a deficiency in petitioners' income tax for the year 1950 in the sum of $7,582.60 together with additions to tax in the sum of $1,722.48, under section 294 of the Internal Revenue Code of 1939 for failing to file a declaration of estimated tax within the time prescribed by law. The only issue presented for our decision in this case is whether respondent correctly determined that an apartment house sold...
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