Memorandum Findings of Fact and Opinion
PARKER, Judge:
Respondent determined deficiencies in and additions to petitioner's Federal income tax as follows:
Docket No. Year Deficiency Sec. 6653(b)1 9797-76 1971 $ 10,274.07 $ 5,137.04 1972 407,862.53 203,931.27 202-78 1973 198,472.50 -0-
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