Memorandum Findings of Fact and Opinion
WITHEY, Judge:
Deficiencies in the income tax of petitioner and additions to the taxes have been determined by the Commissioner for the following taxable years and amounts:
Addition to tax Year Deficiency Section 6653(a)1 1963 ......... $7,935.23 $396.76 1964 ......... 548.75 ...
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