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LOZOSKI v. COMMISSIONER

Docket No. 65083.

18 T.C.M. 1062 (1959)

T.C. Memo. 1959-221

Vincent F. Lozoski and Mary F. Lozoski v. Commissioner.

United States Tax Court.

November 30, 1959.

Attorney(s) appearing for the Case

Paul A. Gorin, Esq., for the petitioners. Manning K. Leiter, Esq., for the respondent.

Memorandum Opinion

OPPER, Judge:

Respondent determined deficiencies in additions to tax as follows:

                      Additions to tax — I. R. C. 1939
  Year                Sec. 294(d)(1)(A)    Sec.294(d)(2)

  1953 ................... $362.44            $255.84
  1954 ...................  108.19              76.37

The sole issue is whether the additions to tax provided by section 294(d)(1)(A) and section 294(d)(2)...

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