Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in the Federal income taxes and additions to the taxes of petitioner Scott C. Rethorst for the years and in the amounts as follows:
Addition to tax under Sec. 6653(a) Year Deficiency I. R. C. 1954 1961 ......... $5,716.50 $285.83 1962 ......... 9,736.60 ...
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