Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined the following deficiencies in and additions to petitioner's income taxes:
Additions to Tax Sec. Sec. Year Deficiencies 6653(b)1 6654 1971 ....... $ 17,153.27 $ 8,576.64 $ 547.59 1972 ....... 14,623.60 7,311.80 466.83 ...
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