Memorandum Findings of Fact and Opinion
WITHEY, Judge:
Respondent determined deficiencies in petitioners' income tax, as well as additions to tax under section 6653(b) of the Internal Revenue Code of 1954,
Year Deficiency Addition to Tax Sec. 6653(b) 1958 ......... $355,237.22 $177,618.61 1959 ......... 349,761.70 174,880.85...
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