Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The respondent determined deficiencies in petitioner's income tax for the years and in the amounts as follows:
Year ended December 31 Deficiency 1956 ................ $ 47,607.70 1957 ................ 77,997.79 1958 ................ 259,471.08 1959 ................ 263,771.03
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