Simpson, Judge: The Commissioner determined deficiencies in the petitioner’s Federal income taxes of $81,931.43 for 1973 and $1,429.80 for 1974. He also determined an addition to tax of $4,096.57 for 1973 under section 6653(a) of the Internal Revenue Code of 1954, 1 but he now concedes that the petitioner is not liable for such addition to tax. After concessions by the parties,…
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