Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioners' income tax for the calendar year 1963 in the amount of $1,364.31 and an addition to tax under the provisions of section 6653(a) of the Internal Revenue Code of 1954 in the amount of $68.22.
The issues for decision are:
(1) Whether one of petitioners received tips as a bartender in 1963...
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