Memorandum Findings of Fact and Opinion
The respondent determined deficiencies in petitioners' income tax and additions to tax as follows:
Additions to Tax --------------------- Sec. 294 Sec. 294 Year Deficiency (d)(1)(A) (d)(2) 1952......... $5,047.82 $490.72 $327.15
The only issue is whether the sum of $10,000 received...
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