Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioner's income tax for the calendar years 1970, 1971 and 1972 in the amounts of $141,814.58,$5,378.83 and $6,758.67, respectively, and an addition to tax under section 6651(a)(1), I.R.C. 1954,
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