Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
This proceeding involves deficiencies in income tax and an addition thereto for the years and in the amounts as set forth below:
Year Deficiency Addition to Tax Section 291(a) 1951............... $12,772.25 ....... 1952............... 17,975.46 ....... 1953............... 21,357.12 $1,067.85
The issues for decision are: (1) Whether respondent...
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