Memorandum Findings of Fact and Opinion
TURNER, Judge:
The respondent determined a deficiency in income tax and additions to tax for the year 1951 against Earl G. Harris and petitioner, formerly husband and wife, as follows:
Additions to Tax, I.R.C. 1939, under Deficiency Sec. 294(d) (1) (A) Sec. 294(d) (2) ______________________________________ $59,274.64 ...
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