Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency in petitioner's 1961 income tax in the amount of $6,226.72 and an addition to tax under section 6653(a), I. R. C. 1954, in the amount of $311.33. The adjustment giving rise to this deficiency was a determination of a $16,245.03 understatement of adjusted gross income computed by "the so-called source and application of funds method." The only two items in controversy in respect of that...
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