Memorandum Findings of Fact and Opinion
In this case respondent determined a deficiency in the Federal income tax of petitioners for the year 1952 in the amount of 10 cents. This deficiency is not here at issue.
For the years 1952 and 1953 respondent determined additions to tax under sections 294(d)(1)(A) and 294(d)(2), Internal Revenue Code of 1939, in the respective total amounts of $347.29 and $216.87. These additions to tax are here in issue.
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