Memorandum Findings of Fact and Opinion
MULRONEY, Judge:
The respondent determined deficiencies in petitioners' income tax and additions to tax for the years 1954 and 1955 as follows:
Additions to Tax, I. R. C. 1939 Sec. 294 Sec. 294 Year Deficiency (d) (1) (A) (d) (2) 1954..... $24,320.23 ...
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