Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The Commissioner determined deficiencies in income tax and additions to tax for the taxable years 1958 and 1959 as follows:
Additions to the tax under section Year Deficiency 6653(b) 1958............ $214,155.63 $107,077.82 1959............ 178,905.74 89,452.87...
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