Memorandum Findings of Fact and Opinion
WHITAKER, Judge:
Respondent determined deficiencies in petitioners' Federal income tax and additions to the tax as follows:
Addition to Tax Year Deficiency Sec. 6653(a)1 1972 ....... $ 4,106.57 $ 205.33 1973 ....... 361,937.60 18,096.88
Respondent conceded the 1972 deficiency,
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