Memorandum Opinion
OPPER, Judge:
In this proceeding deficiencies in income tax and additions to tax were determined as follows:
Additions to Taxable Tax Sec. 293(b), Year Income Tax I. R. C. 1939 1948 ...... $20,149.82 $10,074.91
Although petitioners' counsel was present, he refused to participate in the proceedings and no evidence was produced on petitioners...
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