Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined deficiencies in petitioners' income tax and in additions to tax for the years 1952 and 1953 as follows:
Sec. Sec. Sec. Income 294(d)1 294(d) 294 Year Tax (1)(A) (1)(B) (d)(2) 1952.... $ 297.04 $2,664.07 -0- $1,776...
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