Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined deficiencies in and additions to petitioner's Federal income tax in the following amounts for the indicated taxable years:
Addition to Tax Taxable Sec. 6653(b), Year Deficiency I.R.C. 19541 1970 ........... $104,583.34 $ 52,291.67 ...
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