Memoradum Findings of Fact and Opinion
NIMS, Judge:
Respondent determined the following deficiencies in decedent's income tax and additions to tax:
Sec. 6651(a)1 Sec. 6653(a) Tax Addition Addition Year Deficiency to Tax to Tax 1972 $76,136.09 $3,735.15 $3,855.70 1973 24,092.24 3,581.14 -0-
Petitioner claims...
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