Memorandum Findings of Fact and Opinion
WILBUR, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes and additions to tax as follows:
Additions to Tax under Year Deficiency Sec 6653(a)1 1969 ....... $ 1,902.81 $ 95.14 1970 ....... 321,663.17 16,083.16 1971 ....... 244,444.94 12,222.25 1972 ...
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