Memorandum Findings of Fact and Opinion
QUEALY, Judge:
Respondent has determined deficiencies and additions to the Federal income tax of the petitioners as follows:
Addition to the Income tax Section Year tax 6653(a)1 1961 .... $ 5,654.87 $282.74 1962 .... 37,192.35 ...... 1963 .... 42,249...
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