Memorandum Findings of Fact and Opinion
BRUCE, Judge:
Respondent determined deficiencies in petitioners' income tax and additions to tax for the years 1952 and 1953 as follows:
Addition to Tax Year Deficiency Sec. 294(d) (2) 1952................... $ 8,191.10 $ 555.72 1953................... 25,399.22 1,677.75
Certain adjustments have not been contested...
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