Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in and additions to tax against Albert Barrasso and Marion Barrasso for the years and in the amounts as follows:
Additions to Tax,1 I. R. C. 1954 Year Income Tax Sec. 6653(b) 1965 .......... $370,006.02 $185,003.01 1966 .......... 373,025...
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