Memorandum Findings of Fact and Opinion
ATKINS, Judge:
The respondent determined deficiencies in income tax for the taxable years 1960, 1961, and 1962 in the respective amounts of $9,738.18, $12,381.72, and $306.43, and additions to tax, pursuant to section 6653(a) of the Internal Revenue Code of 1954, in the respective amounts of $486.91, $629.62, and $29.35.
In the petition the petitioner raised a number of issues, but by stipulation all
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