Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The Commissioner determined deficiencies for the year 1951 consisting of the following additions to tax:
Internal Revenue Code of 1939 Sec. 294(d)(1)(A) Sec. 294(d)(2) ------------------------------------ $ 2,393.82 $1,595.88
The propriety of the additions to tax is in issue.
Findings of...
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