Memorandum Findings of Fact and Opinion
QUEALY, Judge:
The respondent determined deficiencies in income tax and additions to tax as follows:
Joe Silverman, Docket No. 2718-68 Addition to Tax, Year Deficiency Sec. 6653(b) 1958 ......... $116,714.92 $58,357.46 1959 ......... 3,065.10 1,532.55 1960 ......... 8,964.25 4,482.12 1961 ......... 8,788.97...
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