Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
Respondent has determined deficiencies in petitioner's income tax and additions to tax as follows:
Additions to Tax Sec. 6653(a), Year Income Tax I. R. C. 1954 1957 .......... $688.29 $34.41 1958 .......... 770.47 38.52
The issues are (1) whether petitioner understated tip...
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