Memorandum Findings of Fact and Opinion
SCOTT, Judge:
The respondent determined deficiencies in petitioner's income tax in the amounts of $3,573.15 and $1,688.56 for the taxable years 1948 and 1949, respectively. Respondent also determined additions to the tax for each of these years under sections 291(a), 294(d)(1)(A) and 294(d)(2) of the Internal Revenue Code of 1939, but at the trial of the case conceded the addition to the tax under section 294(d)(2...
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