Memorandum Findings of Fact and Opinion
TRAIN, Judge:
Respondent determined deficiencies in petitioners' income tax and additions to tax as follows:
Year Deficiency Additions to Tax Under Sec. 293(b)1 1948 ........ $21,783.50 $10,891.75 1949 ........ 182.20 91.10
The issues to be decided are whether petitioners:
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