Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined the following deficiencies and penalties in petitioner's Federal income taxes:
Penalties Sec. Sec. Year Deficiency 6651(a) 6654 1961 ......... $2,868.49 $635.56 $ 64.01 1962 ......... 3,631.01 907.75 101.67 1963 ......... 614.00 153.50 ...
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