Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined deficiencies and additions to tax against petitioner in the following amounts:
Sec. 6653(a)1 Year Deficiency Addition 1969 ........... $74,626.00 $3,732.00 1970 ........... 34,129.00 1,707.00
The sole issue...
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