Memorandum Findings of Fact and Opinion
ATKINS, Judge:
The respondent determined deficiencies in income tax for the taxable years 1956 and 1957 in the respective amounts of $51,326.11 and $107,358.81, and additions thereto under section 6653(b) of the Internal Revenue Code of 1954 in the respective amounts of $25,663.06 and $58,383.41. The issues are whether the petitioners omitted substantial amounts of income from their income tax returns for the taxable...
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