Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined the following deficiencies in, and additions to, petitioner's Federal income taxes:
Additions to Tax Year Deficiency Sec. 6653(b) Sec. 6654(a) 1971 ... $217,682.00 $108,841.00 ...... 1972 ... 217,958.00 108,979.00 ...... 1973 ... 221,032.58 110,516.29 $536.47
At trial...
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