Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
This proceeding involves deficiencies in income tax and additions thereto determined against Peter Casella in the amounts and for the taxable years as set forth below:
Addition to Tax Section 293(b) Year Deficiency I. R. C. 1939 1946......... $11,603.31 $5,801.66 1950......... 3,393.44 1,391...
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