Memorandum Opinion
RAUM, Judge:
The Commissioner determined deficiencies in income tax and additions to tax as follows:
Additions to Tax,1 Sec. 6653(b), Year Deficiency I.R.C. 1954 1975 ....... $137,630.11 $69,509.50 1976 ....... 80,919.72 40,982.73 1977 ....... 31,067.21 15,532.11
The basic...
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