Memorandum Findings of Fact and Opinion
The respondent, in his amended answer, claims only deficiencies and additions to tax as follows:
Additions to Tax I. R. C. 1939 § 294(d) Year Deficiency § 291(a) (1)(A) 1952 ....... $9,951.66 ...... ...... 1953 ....... 1,394.12 $944.13 $332.60
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