Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
Respondent has determined deficiencies in petitioner's income tax for 1959 and 1960 in the respective amounts of $472.79 and $563.36, and additions to these taxes for such years under the provisions of section 6653(a) of the 1954 Code (the so-called 5 percent negligence penalty) in the amounts of $23.64 and $28.17, respectively.
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