Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
Respondent has determined deficiencies in petitioner's income taxes for the calendar years 1960 through 1964 in the following amounts:
Year Deficiency 1960 ................ $ 1,012.26 1961 ................ 7,243.68 1962 ................ 28,800.14 1963 ................ 37,182.43 1964 ................ 33,449.06
In his statutory notice...
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