Atkins, Judge: Respondent determined deficiencies in income tax of petitioners for tbe years 1953 and 1954 in the respective amounts of $547.64 and $423.20, 'and for the year 1953 determined additions to tax under section 294(d) (1) (A) and section 294(d) (2) of the Internal Revenue Code of 1939, in the respective amounts of $184.32 and $122.88. The issue presented is whether…
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