Memorandum Findings of Fact and Opinion
NIMS, Judge:
Respondent determined deficiencies in petitioner's income tax and additions to tax as follows:
Addition to Tax Year Deficiency Section 6653(b)1 1973 .......... $112,780 $56,390 1974 .......... 30,293 15,147 1975 .......... 88,519 44,260 1976 ........
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