Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The Commissioner determined the following deficiencies in and additions to the petitioners' Federal income taxes:
Additions to tax Year Deficiency Sec. 6651(a)1 Sec. 6653(b) 1961 .... $ 1,710.12 ...... $ 855.06 1962 .... 42,955.82 ...... 21,477.91 1963 .... 266.87 ...... ...
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