Memorandum Findings of Fact and Opinion
ATKINS, Judge:
The respondent determined deficiencies in income tax for the years 1958 and 1959 and additions thereto for fraud and underpayment of estimated tax as follows:
Addition to Addition to tax under tax under Year Deficiency § 6653(b) § 6654 1958 ..... $1,736.79 $ 868.40 $ 58.10 1959...
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