Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined the following deficiencies and additions to tax with respect to petitioner's income taxes for the taxable years 1959 through 1963:
Addition to Tax § 6651(a), I. R. C. Year Deficiency 1954 1959 .......... $18,135.86 $4,533.97...
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