Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined deficiencies in petitioner's income taxes and additions to tax for fraud under section 6653 (b), I.R.C. 1954, for the taxable years and in the amounts following:
Addition to tax Year Deficiency sec. 6653(b) 1963 ........ $127,547.77 $63,903.49 1964 ........ 54,159.53 27,209.37 1965 ........ 94,296.40...
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