OPINION
SCOTT, Judge:
The notice of deficiency for petitioner's fiscal year ended June 30, 1955, determined an overassessment in income tax of $12,791.94 and additions to tax under sections 6651(a) and 6653(a) of the Internal Revenue Code of 1954 in the respective amounts of $10,242.61 and $2,048.52. Respondent explained his determination of additions to tax as follows:
It is determined that your failure to file income tax returns for your...
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