PHELAN v. COMMISSIONER

Memorandum Findings of Fact and Opinion

In this case the respondent has determined a deficiency in petitioners' Federal income tax for the year 1952 in the amount of $2,489.10, an overassessment of petitioners' Federal income tax for the year 1951 in the amount of $2,337.08, and additions to tax pursuant to sections 294 (d)(1)(A) and 294(d)(2), as follows:

                      Sec. 294      Sec.
  Year                (d)(1)(A)   294(d)(2)

  1951...

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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