Memorandum Findings of Fact and Opinion
RUWE, Judge:
Respondent determined deficiencies and additions to tax in petitioner's income taxes as follows:
Additions to Tax Year Deficiency Sec. 6653(b)1 1971 ........... $22,833.79 $11,416.89 1972 ........... 7,037.64 3,518.82 1973 ........... 57,075.60 28,537.80...
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