Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined deficiencies in petitioner's Federal income tax and additions to tax as follows:
Additions to Tax Year Deficiency 6653(b)1 6654 1973 ...... $ 14,020 $ 7,010 1974 ...... 174,741 87,371 $ 5,572 1975 ...... 212,579 106,290 9,179 1976...
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