Memorandum Findings of Fact and Opinion
NIMS, Judge:
Respondent determined deficiencies and additions to petitioner's income tax as follows:
Additions to Tax Year Deficiency Section 6653(b)1 1977 .............. $ 64,181 $ 32,091 1978 .............. 243,320 121,660 1979 .............. 514,291 ...
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