Memorandum Findings of Fact and Opinion
BRUCE, Judge:
Respondent determined deficiencies in income tax and additions to tax of petitioner for the calendar years 1950 and 1951 as follows:
Additions to Tax Calendar Income Tax Sec. 294 Sec. 294 Year Deficiency (d)(1)(A) (d)(2) 1950...... $116,036.81 ......... ......... 1951...... 23,284.65 $2,557.98...
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