Memorandum Opinion
FEATHERSTON, Judge:
Respondent has filed a motion for summary judgment under Rule 121 of the Court's Rules of Practice and Procedure in these consolidated cases which involve the following Federal income tax deficiencies and additions to tax under section 6653(b):
Addition to Year Deficiency tax 1960 ......... $30,042.30 $15,021.15 1961...
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