Memorandum Findings of Fact and Opinion
QUEALY, Judge:
The respondent determined deficiencies in the Federal income tax due from the petitioner as follows:
Year Deficiency 1960 ................... $39,159.90 1961 ................... 51,588.00 1962 ................... 51,192.00 1963 ................... 39,387.00 1964 ................... 24,153.00
The respondent has conceded the fraud...
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