Memorandum Findings of Fact and Opinion
PARR, Judge:
Respondent determined deficiencies in and additions to tax as follows:
Docket No. 9178-762 Addition to Tax Year Deficiency Sec. 6651(a)(1) 1969 ............. $46,268.20 $11,567.05 Docket No. 17347-80 Year Deficiency 1979...
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