Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The Commissioner determined a deficiency in income tax of $22,159.02 for the year 1953 and an addition to tax of $1,628.57 under section 294(d)(2), Internal Revenue Code of 1939.
The issue with respect to the addition to tax has been conceded by the Commissioner and the only question for decision is whether petitioner Mary Chelius is properly taxable on the entire proceeds of an undivided one...
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