Memorandum Findings of Fact and Opinion
ATKINS, Judge:
The respondent determined deficiencies in income tax for the taxable years 1961 and 1962 in the respective amounts of $23,133.40 and $18,719.14, and an addition to tax, under section 6654 of the Internal Revenue Code of 1954, for the taxable year 1961 in the amount of $177.70, for underpayment of estimated tax.
The petitioners having conceded liability for the addition to tax, the only remaining...
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