Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The respondent has determined deficiencies in the petitioner's income tax and additions to tax under section 293(a) of the Internal Revenue Code of 1939 for the indicated years as follows:
Addition to tax Income tax sec. 293(a) Year deficiency I. R. C. 1939 1950......... $11,300.66 $ 565.03 1951.......
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