Memorandum Findings of Fact and Opinion
QUEALY, Judge:
The respondent has determined deficiencies in the Federal income tax and additions to the taxes of the petitioners as follows:
Addition to the tax Sec. 6653(b), Year Deficiency I. R. C. of 1954 1959 ...... $ 94,312.40 $ 47,156.20 1960 ...
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