Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioners' income tax and additions to the tax as follows:
Additions to Tax under Deficiency in Sec. 294(d), Year Income Tax I. R. C. 1939 1950 ....... $ 18,902.06 .......... 1951 ....... 17,285.07 ...
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