Memorandum Opinion
WILBUR, Judge:
Respondent determined deficiencies in petitioner's Federal income tax and addition sto tax as follows:
Additions to Tax Year Tax Under Ending Deficiency Sec. 6653(b)1 April 30, 1971 .......... $60,636.34 $30,318.17 April 30, 1972 .......... $47,485.11 $23,742.56
The deficiencies...
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