Memorandum Opinion
DAWSON, Judge:
In these consolidated cases respondent determined the following deficiencies in petitioner's Federal income taxes and additions to tax:
Addition to Tax Year Deficiency Section 6653(b)1 1973 ..... $ 6,890.17 $3,445,09 1974 ..... 11,833.32 5,916.91
On November 6, 1981, respondent filed a motion for summary...
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