Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in the Federal income tax of petitioner, Badias & Seijas, Inc. in the amounts of $102,345.03, $96,513.97 and $96,562.18 for the calendar years 1969, 1970 and 1971, respectively. Respondent also determined additions to tax under section 6653(b), I.R.C. 1954,
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