Memorandum Findings of Fact and Opinion
SHIELDS, Judge:
The respondent determined that there are deficiencies in income tax and additions to tax due from the petitioners as follows:
Additions to Tax Under Year Deficiency Sec 6653(b)(1)1 1957...... $436,776.42 $218,518.07 1958...... 755,349.40 377,817.20 1959.........
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