Memorandum Findings of Fact and Opinion
WILES, Judge:
The respondent determined the following deficiencies in, and additions to, the income tax of petitioner:
Taxable Year Asserted Section 6651(a)1 Ended Jan. 31 Deficiency Addition to Tax 1962 ......... $202,596.57 $50,649.14 1963 ......... 66,385.05 16,596.26 1964 ......... 39,833.91 9,958.48 1965 ......
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