Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The Commissioner determined the following deficiencies in income tax and additions to tax against the petitioners:
1954 Code Additions to Tax Under Under Sec. Sec. Year Deficiency 6651(a) 6653(a) 1959 ...... $1,161.47 $17.26 $ 94.10...
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