Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined deficiencies and additions to tax in petitioner's 1974 and 1976 Federal income taxes as follows:
Additions to Tax sec. sec. sec. Year Deficiency 6651(a)1 6653(a) 6654 1974 .. $ 7,921.31 $ 1,980.33 $ 396.07 $ 253.48 1976 .. 99,224.14 24,806...
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