Memorandum Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioners' income tax and addition to tax under section 6653(b), I. R. C. 1954, for the calendar year 1958 in the amounts of $914,152.23 and $457,076.12, respectively, and for the calendar year 1959 in the amounts of $3,220,974.01 and $1,610,487.01, respectively.
Petitioners are husband and wife residing in Kew Gardens, Long Island, New York.
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