Memorandum Findings of Fact and Opinion
ATKINS, Judge:
The respondent determined deficiencies in income tax and additions thereto for the years and in the amounts as follows:
Additions under I. R. C. of 1939 ----------------- Sec. 294 Sec. 294 Year Deficiency (d)(1)(A) (d)(2) 1949..... $ 9,683.63 ...
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