Memorandum Findings of Fact and Opinion
HAMBLEN, Judge:
Respondent determined the following deficiencies in, and additions to, petitioner's Federal income taxes:
Sec. 6653(b)1 Year Deficiency Addition 1973 ............. $37,379.49 $18,689.75 1974 ............. 1,987.25 993.63
The issues for decision are: (1) Whether respondent...
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