Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioner's income tax for the years 1955, 1956, and 1957 in the amounts of $95,214.24, $4,518.13, and $57,944.38, respectively, and additions to the tax under section 6653(b) of the Internal Revenue Code of 1954 for these years in the respective amounts of $47,607.12, $2,259.07, and $28,972.19.
The only issue for decision is whether petitioner is entitled...
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