Memorandum Findings of Fact and Opinion
RAUM, Judge:
The Commissioner determined the following deficiencies in income tax and additions to tax for the years 1973 and 1974:
Additions to Tax, I. R. C. 1954 Sec. Sec. Sec. Year Deficiency 6651(a) 6653(a) 6654(a) 1973 .... $17,395* $2,909.45...
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