Memorandum Findings of Fact and Opinion
BRUCE, Judge:
The respondent determined deficiencies in income tax for the calendar years 1959 and 1960 and additions to tax under section 6653(a) of the Internal Revenue Code of 1954 for negligence or intentional disregard of rules and regulations, in the following amounts:
Additions to Tax Sec. 6653(a) Year Deficiency I. R. C. 1954...
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