Memorandum Findings of Fact and Opinion
ATKINS, Judge:
The respondent determined deficiencies in income tax and additions thereto for the years and in the amounts as follows:
I. R. C. 1939 Sec. Sec. 294 Year Income Tax 293(b) (d)(2) 1948....... $109,100.56 $54,550.28 $6,486.42 1949....... 40,178.00 20,089.00 2,500.62 1950...
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