OPINION
RAUM, Judge:
The Commissioner determined deficiencies and additions to tax against petitioners as follows:
Additions to tax, I.R.C. 1954 Year Deficiency Sec. 6653(a) Sec. 6652(t) [sic] 1976 $14,340,296 $717,015 1977 20,356,133 1,017,807 $5,000
The deficiencies are based upon numerous...
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