Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined the following income tax deficiencies and additions to tax:
Additions to Tax Sec. Sec. Year Deficiency 6651(a) 6653(a)1 1960............... $ 25.90 $ 6.53 $3.57 1961............... 434.98 108.75 21.75 1962...............
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