Memorandum Findings of Fact and Opinion
RAUM, Judge:
The Commissioner determined deficiencies in Federal income tax against petitioners Bert and Rita M. Kreisberg for the calendar year 1973 in the amount of $956,632, and deficiencies in income tax and additions to tax against transferor Bert Kreisberg & Associates, Inc., as follows:
Addition to Tax, Taxable Year I.R.C. 1954, ...
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