Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioner's income taxes and additions to tax under section 6653(a) of the Internal Revenue Code of 1954 for the calendar years 1959 and 1960 in the amounts of $435.42 and $421.50 and the amounts $21.77 and $21.08, respectively.
The issues for decision are whether petitioner had income from tips in excess of the amount reported on his Federal income tax return...
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