Memorandum Findings of Fact and Opinion
TURNER, Judge:
The respondent determined deficiencies in income tax and additions to tax under section 291(a) of the Internal Revenue Code of 1939, for failure to file returns, and under section 294(d)(1)(A) of the said Code, for failure to file declarations of estimated tax, against the petitioners for the years 1950 and 1951, as follows:
Additions to Tax ...
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