Memorandum Findings of Fact and Opinion
The Commissioner has determined a deficiency in petitioners' income tax for the year 1954 of $4,227.63. He has also determined additions to tax for said year of $297.54 under section 294(d)(1)(A), and $198.36 under section 294(d)(2), I. R. C. 1939. The deficiency results from one adjustment to the income as reported on the joint return which the petitioners filed for the year 1954. That adjustment was "(a) Earnings from fishing...
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