Memorandum Findings of Fact and Opinion
JACOBS, Judge:
Respondent determined deficiencies in petitioner's Federal income tax and additions to tax as follows:
Additions to Tax Year Deficiency Section 6653(b)1 1973 ............ $13,790 $ 6,895 1974 ............ 27,430 13,715 1975 ............ 15,205 ...
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