Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
In these consolidated proceedings, respondent determined the following income tax deficiencies and additions to tax under section 6653(a):
Docket No. 2518-75—Saul S. Pearl, et ux. Penalty Calendar Year Deficiency (sec. 6653(a)) 1970 ........ $71,887.31 -0- Docket No...
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