Memorandum Findings of Fact and Opinion
PIERCE, Judge:
Respondent determined deficiencies in the income taxes of petitioners, and additions to tax for fraud under section 293(b) of the 1939 Code, for calendar years and in amounts as follows:
Calendar Addition to tax year Deficiency under Sec. 293(b) 1950.......... $22,902.60 $11,451.30 1951.......... 22,320.80 11,160.40 ...
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