Memorandum Findings of Fact and Opinion
WITHEY, Judge:
Respondent determined income tax deficiencies and additions to tax in these consolidated cases as follows:
Docket No. 2761-62 Additions to tax, I. R. C. 1954 Sec. Sec. Year Deficiency 6654 6651(a) 1955 ............ $59,786.06 1956 ....
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