Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The Commissioner determined the following deficiencies in, and addition to, the petitioners' Federal income taxes:
Sec. 6651(a)1 Year Deficiency Addition 1963 ............ $439,812.26 ....... 1965 ............ 104,307.49 ....... 1966 ............ 201,949.08 ....... 1967 ...........
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