Memorandum Findings of Fact and Opinion
WRIGHT, Judge:
By notice of deficiency dated July 13, 1982, respondent determined the following deficiencies and additions to tax due from petitioner:
Additions to Tax Year Deficiency Sec. 6653(b)1 1970 .................. $94,276.94 $47,138.47 1971 .................. 20,115...
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