Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The Commissioner determined the following deficiencies in income tax and additions to tax:
Additions to Tax...I. R. C. 1939 Year Income Tax Sec. 294 Sec. 294 (d)(1)(A) (d)(2) 1952 ..... $ 2,248.86 1953 ..... 14,605.86 $1,265.39 $813.59
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