SCHOENBERG v. COMMISSIONER

Memorandum Findings of Fact and Opinion

TRAIN, Judge:

Respondent determined deficiencies in petitioner's income tax and additions to tax under section 294(d)(2) of the Internal Revenue Code of 1939 for the years and in the amounts as follows:

                                Additions to
                                Tax Section
  Year             Deficiency    294(d)(2)

  1952.........    $44,018.48    $2,730.76
  1954.........      6...

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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