MEMORANDUM FINDINGS OF FACT AND OPINION
FAY, Judge:
Respondent determined the following deficiencies in, and additions to, petitioner's Federal gift taxes:
Additions to Tax ------------------------------ Quarter Ending Deficiency Sec. 6651(a)(1) Sec. 6653(a) Mar. 31, 1980 $1,248,737 $312,184 $62,437 June 30...
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