Memorandum Findings of Fact and Opinion
WITHEY, Judge:
Deficiencies in the income tax and additions to the tax have been determined by respondent as follows:
Additions to tax Sec. Sec. 6653(b) 294(d)(2) Income tax I. R. C. I. R. C. Year deficiency 1954 1939 1954...... $26,946...
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