KATZ v. COMMISSIONER

Memorandum Findings of Fact and Opinion

TRAIN, Judge:

The respondent determined deficiencies in the petitioners' income tax and additions to tax, for the years and in the amounts, as follows:

                              Additions to Tax
                            Sec.       Sec.
  Taxable                  294(d)    294(d)    Sec. 294
   Year       Deficiency  (1)(A)   (1)(B)    (d)(2)

   1951.....  $1,764.86   $205.59  ......    ......

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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