Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in the income taxes of petitioners Henry J. Moravec, Sr. and Vlasta Moravec for the calendar years 1962 and 1963 in the amounts of $57,750.24 and $145,145.36, respectively, and an addition to tax under section 6653(b), I. R. C. 1954,
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