Memorandum Findings of Fact and Opinion
IRWIN, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes as follows:
Parker Tree Farms, Inc. (Docket No. 5431-76) Additions to Tax Sec. Sec. Year Deficiency 6651(a)(1) 6653(a) 1968 .... $125,435.26 $31,433.82 $6,271.76 1970 .... 3,803.65 950.91 ...
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