PINKHAM v. COMMISSIONER

Memorandum Findings of Fact and Opinion.

Respondent determined deficiencies in petitioner's income tax and additions to tax under sections 291(a), 293(a), 294 (d)(1)(A), and 294(d)(2) of the Internal Revenue Code of 1939, for the taxable years 1948, 1949, and 1950, as follows:1

                         Additions to tax under sections
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