SUPPLEMENTAL FINDINGS OF FACT AND OPINION
TANNENWALD, Judge:
This case is now before the Court on remand from the Sixth Circuit. In his notice of deficiency, respondent determined certain deficiencies in petitioner's income taxes for 1963, 1964, and 1965. He also determined additions to the tax in each year under section 6653(b), I.R.C. 1954, but prior to the original trial herein he waived any claim for such additions. In our prior opinion (
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