Memorandum Findings of Fact and Opinion
ATKINS, Judge:
The respondent determined deficiencies in income tax for the years 1948 to 1951 and additions thereto as follows:
Additions to Tax Year Deficiency Sec. Sec.294 Sec.294 291(a) (d)(1)(A) (d)(2) 1948....... $8,617.80 ........ $889.07 $533.43 1949....... 9,464.02 ........ ....... 603.11...
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