Memorandum Findings of Fact and Opinion
STERRETT, Judge:
In his notice of deficiency dated September 16, 1977, respondent determined the following additions to tax in petitioner's income taxes:
Addition to Tax Year (Sec. 6653(b)) 1969 .............. $14,315.40 1970 .............. 25,069.76 1971 .............. 44,853.34
The only question before this Court is whether the underpayments...
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