Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioner's income taxes and additions to tax for the years and in the amounts as follows:
Deficiencies Additions to Fiscal Year in Tax, I.R.C. 1954 Ending Income Tax Sec. 6653(a)1 October 31, 1973 ... $ 7,821 $ 391 October 31, 1974 ... 26,291...
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