Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined deficiencies in petitioner's income taxes as follows:
Addition to tax under sec. Year Tax 6653(a)1 1959........ $4,657.11 $232.86 1960........ 6,054.82 302.74 1961........ 4,516.19 231.811
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