Memorandum Opinion
BRUCE, Judge:
This case involves respondent's determination of (1) a deficiency in petitioner's income tax for the calendar year 1951 in the amount of $9,378.36, (2) additions to tax for such year under section 294(d), Internal Revenue Code of 1939, in the aggregate amount of $633.65; and respondent's allegation of an additional deficiency for such year in the amount of $1,130.14.
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