Memorandum Findings of Fact and Opinion
TRAIN, Judge:
Respondent determined deficiencies in income tax and an addition to tax for the calendar years and in the amounts as follows:
Addition to Tax Sec. 294(d)(2) Year Deficiency 1939 Code 1949...... $ 1,233.92 1950...... 6,438.20 1952...... 51,480.33 $3,304.27 1954...... 3,002.43 1955...... ...
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