Memorandum Findings of Fact and Opinion
TRAIN, Judge:
Respondent determined a deficiency in addition to income tax of the petitioners for the taxable year 1954 in the amount of $927.93 for failure to file a declaration of estimated tax and for substantial underestimation of estimated tax, as provided by sections 294(d)(1)(A) and 294 (d) (2) of the Internal Revenue Code of 1939.
The issues are: (1...
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