Memorandum Findings of Fact and Opinion
BRUCE, Judge:
Respondent determined deficiencies in petitioner's income tax for the years 1949, 1950, and 1951, and addition to tax for the year 1951, as follows:
Addition to Tax Year Deficiency Sec. 294(d)(2) 1949............ $1,749.10 ...... 1950............ 5,041.33 ...... 1951............ 2,211.88 $331...
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