Memorandum Findings of Fact and Opinion
Respondent determined deficiencies in petitioners' Federal income taxes for the years 1952, 1953, and 1954 in the respective amounts of $22.45, $100.96, and $74.11, and additions to tax under sections 294(d)(1)(A) and 294(d)(2) of the Internal Revenue Code of 1939 for the years 1952 and 1953 as follows:
Section Section 294(d)(1)(A) 294(d)(2) 1952...... $29.34 $19.56 ...
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