Memorandum Findings of Fact and Opinion
WILLIAMS, Judge:
The Commissioner determined deficiencies in, and additions to, petitioner's Federal income tax as follows:
Year Deficiency 66511 6653(a) 6653(a)(1) 6653(a)(2) 6654 1978 ................... $ 303,032 $ 75,758 $15,152 ___ ___ $ 9,674 1979 ........
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