Memorandum Opinion
TIETJENS, Judge:
The Commissioner determined deficiencies in petitioners' income tax for the years 1947 through 1951 and made additions to the tax for negligence and for substantial underestimate of estimated tax under sections 293(a) and 294(d)(2) of the Internal Revenue Code of 1939, respectively, as follows:
Sec. 294 Year Deficiency Sec. 293(a) (d)(2) ...
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