Memorandum Findings of Fact and Opinion
For the taxable year 1946, the respondent determined a deficiency in income tax in the amount of $2,995.81; a 50 per cent addition to the deficiency under section 293(b), 1939 Code, in the amount of $1,497.91; an addition under section 294(d)(1)(A) in the amount of $252.18; and a 6 per cent addition under section 294(d)(2) in the amount of $168.13.
The chief questions are whether petitioners realized and failed to...
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