Memorandum Opinion
WILBUR, Judge:
Respondent determined the following deficiencies in the Federal income tax of petitioner:
Sec. 6651(a)1 Year Deficiency addition 1959 ........... $113,657.80 ........ 1960 ........... 90,523.00 $9,052.30 1961 ........... 76,659.53 ........ 1962 ........... 396,900.67 ........
A substantial...
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