Memorandum Findings of Fact and Opinion
TURNER, Judge:
The respondent determined deficiencies in income taxes and addition to the tax for the years 1954 and 1955 as follows:
Year Deficiency Addition to Tax Sec. 294(d) (2), 1939 Code 1954 $ 833.99 ................ $303.72 1955 6,768.54 ................ -0-
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