Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency in income tax of petitioners in the amount of $3,547.94 for the year 1961.
The sole question for decision is whether the Commissioner erred in determining that petitioner Dominic Fiaschetti realized a taxable net gain of $13,200 from wagering at race tracks during the year 1961.
Other issues raised by the pleadings have been settled by stipulation.
Findings...
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