Memorandum Findings of Fact and Opinion
IRWIN, Judge:
Respondent determined the following deficiencies in petitioner's income tax and penalties:
Sec. 6653(b) Year Deficiency Penalty 1961 ................. $11,549.18 $5,774.59 1962 ................. 15,247.76 7,623.88 1963 ................. 12,225.78 6,112.89 1964 ................. ...
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