Memorandum Findings of Fact and Opinion
BRUCE, Judge:
Respondent determined deficiencies in income tax and additions to tax as follows:
Addition to Tax ---------------------------------- Docket No. Year Deficiency Sec.294(d)(1)(A) Sec. 294(d)(2) 56780 ... 1952 $4,715.28 ...... ..... 57384 ... 1952 5,102.76 ...
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