Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioner's income tax and additons to tax for the years and in the amounts as follows:
Additions to Tax Under I. R. C. 1954 Year Deficiency Sec. 6653(a) Sec. 6653(b) 1961 ..... $ 351.94 $17.60 ........ 1962 ..... 3,343.40 ...... $1,671.70
The...
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