Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes as follows:
Taxable Section Section Section Section Year Ended Deficiency 6661 6651(a)(1) 6653(a)(1) 6653(a)(2) May 31, 1981 ........ $477,484 $ 0 $113,621 $23,874 ...
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