Memorandum Findings of Fact and Opinion
PIERCE, Judge:
The respondent determined a deficiency in the income taxes (included in which was a deficiency in self-employment tax) of the petitioner for the calendar year 1955 in the amount of $97,437.75; and he also determined the following additions to tax: (1) For fraud, under section 6653(b) of the 1954 Code, in the amount of $48,718.88
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