Memorandum Findings of Fact and Opinion
Respondent has determined deficiencies in the income tax of petitioner and additions to tax for the years 1953 and 1954, as follows:
Additions to Tax* --------------------------------------- Sec. Sec. 294 Sec. 294 Year Deficiency 291(a) (d)(1)(A) (d)(2) 1953 ........ $3,986.48 ...
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