Memorandum Findings of Fact and Opinion
TRAIN, Judge:
Respondent determined deficiencies in income taxes and additions to tax of the petitioner as follows:
Additions to Tax Taxable Sec. Year Deficiency Sec. 293(b) 294(d)(2) 1946 ........ $ 588.43 $ 294.21 $ 57.15 1947 ........ 19,395.77 9,697.88 1,242.45 1948 .........
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