Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies in petitioner's income tax and additions to tax, as follows:
Additions to Tax, Sec. 6651(a), Year Deficiency I. R. C. 1954 1958 ....... $12,551.48 ....... 1959 ....... 17,464.75 $2,619.72 1960 ....... 25,405.92 4,988.92...
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