SEMEL v. COMMISSIONER

Memorandum Findings of Fact and Opinion

FORRESTER, Judge:

The respondent determined deficiencies in the petitioner's income tax and additions to the tax as follows:

                                         Addition to Tax
                                          Sec. 6653(a),
Year                        Deficiency     I.R.C. 1954

1955 ....................   $ 8,117.70       $405.89
1956 ....................     9,622.20        ......
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