Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined the following deficiencies in petitioner's Federal income taxes:
Additions to Tax Year Deficiency Sec. 6653(b)1 Sec. 6654(a) 1975 ............ $ 48,193.00 $ 24,097.00 $2,076.34 1976 ...
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