Memorandum Findings of Fact and Opinion
RAUM, Judge:
Petitioners are husband and wife. They filed a joint income tax return for 1950 on March 15, 1951. On April 22, 1955, the Commissioner sent to them a notice of deficiency in the amount of $199.02 plus an addition to tax in the amount of $101.70 pursuant to Section 294 (d)(1)(A) of the 1939 Code and a further addition in the amount of $62.48 pursuant to Section 294(d)(2). The question for decision is whether...
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