PERRY v. COMMISSIONER

Memorandum Findings of Fact and Opinion

PIERCE, Judge:

Respondent determined deficiencies in petitioners' income tax, and additions to tax for substantial underestimate of estimated tax (section 294(d) (2) of the 1939 Code) and for underpayment of estimated tax (section 6654 of the 1954 Code), as follows:

                               Additions to Tax
                              Sec. 294
  Year          Deficiency     (d)(2)     Sec. 6654...

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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