Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes and additions to tax as follows:
Addition Year Deficiency Sec. 6653(b)1 1960 ....... $45,773.64 $22,886.82 1961 ....... 37,530.82 18,765.41 1963 ....... 22,264.09 ...
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