Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined deficiencies in the income taxes of petitioners in the amounts of $65,465.22 and $74,361.10 for the taxable years 1959 and 1960, respectively. Respondent also determined an addition to tax under the provisions of section 6653(a), Internal Revenue Code of 1954
The parties have stipulated that...
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