Memorandum Findings of Fact and Opinion
BRUCE, Judge:
The respondent determined deficiencies in income tax and additions to tax for the calendar years and in the amounts as follows:
Additions to Tax, I. R. C. 1939 Sec. 294 Sec. 294 Year Deficiency 293(b) (d)(1)(A) (d)(2) 1951 .......
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