Memorandum Findings of Fact and Opinion
TRAIN, Judge:
Respondent determined deficiencies in income tax and additions to tax under section 294(d) of the Internal Revenue Code of 1939 in the years and in the amounts as follows:
Additions to Tax Year Docket Deficiency Sec. 294(d) 1951 53143.......... $3,203.22 $ 512.51 1952 60013...
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