Memorandum Findings of Fact and Opinion
QUEALY, Judge:
Respondent determined deficiencies in petitioners' Federal income tax as follows:
Docket No. 1649-67 Taxable Deficiency Year Tax § 6654(a) § 6653(a) 1956 ......... $167,880.59 $79.38 $8,394.03 1957 ......... 212,480.39 ..... 10,624.02 1958 ......... ...
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