Memorandum Findings of Fact and Opinion
The Commissioner has determined deficiencies in additions to tax, I. R. C. 1939, against petitioners for the year 1953 as follows:
Additions to Tax Sec. 294 Sec. 294 Year Tax (d)(2) (d)(1)(A) 1953 ............ None $267.27 $400.90
Petitioners contest this determination of the Commissioner by appropriate assignments...
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