Memorandum Findings of Fact and Opinion
TRAIN, Judge:
Respondent determined deficiencies in the petitioners' income tax and additions to the tax as follows:
Additions to Tax Sec. Year Deficiency 294(d)(2) 1948 ........... $ 6,887.28 ...... 1949 ........... 9,437.09 ...... 1950 ........... 14,047.72 ...... 1951 .....
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