Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioners' income tax for the calendar years 1954 and 1955 in the amounts of $4,797.86 and $40.38, respectively, and additions to the tax for the calendar year 1954 under sections 294(d)(1)(A) and 294 (d)(2) of the Internal Revenue Code of 1939 in the amounts of $389.90 and $352.73, respectively.
Petitioners...
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