Memorandum Findings of Fact and Opinion
FISHER, Judge:
Respondent, in his statutory notice, determined a deficiency in petitioners' income tax for the taxable year 1951 in the amount of $125.97, and additions to tax under section 294(d)(2) and 294(d) (1) (A), Code of 1939, in the amounts of $324.90 and $487.33, respectively. Respondent concedes the issue involving section 294 (d) (2) on the authority of Commissioner v. Acker,
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