Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined the following deficiencies and penalties with respect to petitioner's income taxes for the taxable years 1959 through 1961, inclusive:
Penalty Penalty Year Deficiency Sec. 6651(a) Sec. 6653(a) 1959 ..... $23,274.16 ...... $1,163.71 1960 ..... 4,597.23 $353.83 453.83 1961...
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