Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined deficiencies in petitioners' income tax and additions to tax as follows:
Addition to Tax, I. R. C. 1939 Deficiency Sec. 294 Sec. 294 Year (d)(1)(A) (d)(2) 1953 .... $ 114.30 ...... ...... 1954 .... 5,854.81 $686.05...
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