Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined deficiencies in petitioners' income tax in the respective amounts of $504.24, $432.48, and $436.10 for the years 1955, 1956, and 1957; and, for the same years, by amended answer, claims additions to tax for "negligence" under section 6653(a), I. R. C. 1954, in the respective amounts of 5 percent of the deficiencies. The issues are whether income from tips as was understated; whether...
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