Memorandum Findings of Fact and 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) 1952............. $173.41 $115.60
The issues are (1) whether petitioners' failure to file a declaration of estimated tax was due to reasonable cause and not willful neglect; (2) whether an addition...
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