OPINION.
FORRESTER, Judge:
The Commissioner has determined a deficiency in petitioners' income tax for the calendar year 1951 in the amount of $2,522.64 and addition to tax for substantial underestimation of tax under section 294 (d) (2) in the amount of $151.36. Petitioners have conceded one other issue by stipulation. The facts have been wholly stipulated and are included herein by reference.
Petitioners R. L. McMurtry and Mary P. McMurtry...
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